Darwin LNG Plant · Darwin Regional Land Use Structure Plan 1990. The main process flare has been relocated to the south of the process area also as a result of this transport corridor

Darwin LNG Plant Environmental Management Programme

Volume I – EMP Overview and Compliance Audit Register Distribution List

Assigned To: Programme Copy Number:

Northern Territory Government 1 Northern Territory Government 2 Northern Territory Government 3 Northern Territory Government 4 Northern Territory Government 5 Environment Australia 6 Environment Australia 7 DLNG Operations Manager 8 DLNG HSE Specialist 9 DLNG Project Manager 10 DLNG Project File 11 COP Principal Consultant – Waste & RCRA 12 Darwin Area Manager 13 Darwin Library 14 HSE Manager – Perth 15 Environmental Specialist – Perth 16 Operations VP – Perth 17 Capital Projects VP – Perth 18 Perth Library 19 Bechtel – Houston 20 Bechtel – Houston 21 URS – Perth 22 URS – Darwin 23 URS – Library 24 Darwin Office – spare copy 25 Darwin Office – spare copy 26 Darwin Office – spare copy 27 Darwin Office – spare copy 28 Darwin Office – spare copy 29 Darwin Office – spare copy 30

URS Australia Pty Ltd Level 3, Hyatt Centre, 20 Terrace Road East Perth Western Australia 6004 Job No.: 00533-255-562 Tel.: (08) 9221 1630; Fax: (08) 9221 1639 Report No.: R907, Revision 0 E-mail: [email protected] Ref: DK:M&C1629/PER ABN 46 000 691 690

DARWIN LNG PLANT

ENVIRONMENTAL MANAGEMENT PROGRAMME Volume I – EMP Overview and Compliance Audit Register

Prepared for

Phillips Petroleum Company Australia Pty Ltd and Darwin LNG Project

4 October 2002

TABLE OF CONTENTS

Darwin LNG Plant – Environmental Management Programme, Volume I 00533-255-562/R907(M&C1629) : Revision 0, 4 October 2002 Page i

1. INTRODUCTION............................................................................................. 1

1.1 This Document ................................................................................................ 1 1.2 Background ..................................................................................................... 1

1.2.1 1998 Preliminary EMP for 3 MTPA LNG Plant and Subsea Pipeline .................................................................................. 1 1.2.2 March 2002 Public Environment Report for 10 MTPA LNG Plant .. 2 1.2.3 August 2002 Notice to Construct First LNG Train to 3.24 MTPA

Capacity.............................................................................................. 6 1.3 Structure of EMP Volume I............................................................................. 8 1.4 Purpose and Objectives of EMP...................................................................... 8 1.5 Health, Environment and Safety Management ............................................... 8 1.6 Proponent’s Corporate HES Policy ................................................................. 9 1.7 Proponent’s Commitments ............................................................................ 10

2. EMERGENCY RESPONSE MANUALS ....................................................... 33

2.1 Construction Phase ........................................................................................ 33 2.2 Operations Phase ........................................................................................... 33

3. OIL SPILL CONTINGENCY PLANS ............................................................ 35

4. CORPORATE RELATIONS PLAN............................................................... 36

4.1 Introduction ................................................................................................... 36 4.2 Corporate Relations Manager........................................................................ 36 4.3 Larrakia Liaison Committee.......................................................................... 36 4.4 Stakeholder Liaison Committee .................................................................... 36 4.5 Heritage Issues Advisory Committee............................................................ 37 4.6 Darwin Airport Link...................................................................................... 37 4.7 Public & Community Relations .................................................................... 37 4.8 Internet Web Site........................................................................................... 37

5. COMPLIANCE AUDITING AND REPORTING............................................. 38

5.1 Overview ....................................................................................................... 38 5.2 Environmental Compliance and Auditing Procedures (Construction Phase) ..................................................................................... 50

5.2.1 Environmental Responsibilities (Contractor and Sub-contractors) .. 50 5.2.2 Environmental Responsibilities (Owner) ......................................... 51

5.3 Sustainability ................................................................................................. 51

TABLE OF CONTENTS

Darwin LNG Plant – Environmental Management Programme, Volume I 00533-255-562/R907(M&C1629) : Revision 0, 4 October 2002 Page ii

6. GLOSSARY .................................................................................................. 53

7. REFERENCES.............................................................................................. 55

LIST OF TABLES Table 1.1 Summary of Recommendations from 2002 DIPE Assessment Report 39 and EA Review and Assessment Report (August 2002) ............................... 12 Table 1.2 Summary of Environmental Management Commitments for the Darwin LNG Project ..................................................................................... 18 Table 5.1 Environmental Compliance and Audit Table for the Darwin LNG Project .. 39

LIST OF FIGURES Figure 1 Plant layout for 3 MTPA LNG Plant Originally Approved in 1998 ............... 4 Figure 2 Plant layout for 10 MTPA LNG Plant Approved in 2002............................... 5 Figure 3 Phillips’ Process for Safety and Environmental Excellence ......................... 11

LIST OF APPENDICES A Environmental Assessment Report and Recommendations, by the Office of

Environment & Heritage, DIPE, May 2002 B Review and Assessment of Environmental Aspects, by the Environment Australia

Environment Assessment & Approvals Branch, August 2002

Darwin LNG Plant – Environmental Management Programme, Volume I 00533-255-562/R907(M&C1629) : Revision 0, 4 October 2002 Page 1

1. INTRODUCTION 1.1 THIS DOCUMENT This is the first of a number of documents which together, will form the complete Environmental Management Programme (EMP) for the Darwin Liquefied Natural Gas (DLNG) Project on Wickham Point in Darwin Harbour. At this stage, four volumes of the EMP are envisaged as follows: • Volume I – EMP Overview and Compliance Audit Register (This Document); • Volume II – Construction Phase EMP is specific to managing environmental factors

relevant to the initial phases of site clearing and construction for the DLNG Project; • Volume III - Dredge and Spoil Disposal Construction Phase EMP will be finalised to

manage environmental considerations of relevance to dredging activities, and will also include Oil Spill Contingency Plans for marine works; and

• Volume IV – Operations EMP for the safe and environmentally responsible operation of the LNG Project, including detailed emergency response manuals and ongoing monitoring commitments.

The individual EMP’s have been structured to build on the overarching environmental management framework previously outlined in the Preliminary Environmental Management Programme (Dames & Moore, 1998) (see Section 1.2.1 below). The staged development of the EMP reflects the logical focus on environmental planning for issues which are of relevance to a particular stage of project development (ie. construction, dredging, commissioning and operation). Once accepted by the Department of Infrastructure, Planning and Environment (DIPE) and Environment Australia (EA), the EMP will become a public document and will be made available on an internet website. 1.2 BACKGROUND 1.2.1 1998 Preliminary EMP for 3 MTPA LNG Plant and Subsea Pipeline Phillips Oil Company Australia (Phillips) prepared a Preliminary EMP for the Darwin LNG Plant in 1998 after Government approval was granted to construct and operate a 3 Million Tonnes Per Annum (MTPA) LNG plant on Wickham Point. This Preliminary EMP was released in November 1998 (D&M 1998) after review and approval by NT and Commonwealth regulatory authorities. The Preliminary EMP was designed to capture all the Proponent’s environmental management commitments, plus Ministerial approval conditions applicable to the 3 MTPA LNG project and subsea pipeline between the LNG plant at Darwin, and the Bayu-Undan field central processing platform in the Timor Sea. As such, the document contained the following major components: • A Pipeline Environment Plan (which addressed issues associated with the construction

and operation of the subsea pipeline from Bayu-Undan, through Darwin Harbour to Wickham Point);

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• A Dredging and Spoil Disposal Management Plan (which addressed issues related to the dredging and disposal of materials at the load out jetty and in the vicinity of the construction dock);

• An LNG Plant Environment Management Plan (incorporating management requirements for both the construction and operation phases of the plant);

• An Emergency Response Plan (which outlined the risk assessment process to be followed to produce the response manuals required for various components of the project);

• Oil Spill Contingency Plans (for various components of the project, ie, shipping, offshore platform, pipeline, and Darwin harbour);

• A Corporate Relations Plan ( which addressed communication and transparency issues related to keeping the community informed of developments); and

• A Compliance Auditing and Reporting Plan (which outlined the proposed compliance auditing and reporting framework for the project).

The above document still exists and is referenced as the 1998 Preliminary EMP. Phillips subsequently initiated detailed design of the Bayu-Undan field development but postponed the LNG Plant and pipeline due to the global economic situation sparked by the Asian financial crisis. Subsequently in late 2000, Phillips initiated detailed design of the subsea pipeline to the stage that a Pipeline Environment Plan is now completed and has been submitted to Department of Business, Industry and Resource Development (DBIRD) as a separate deliverable to support the permit applications for the Bayu-Undan to Darwin subsea pipeline. 1.2.2 March 2002 Public Environment Report for 10 MTPA LNG Plant In mid-2001, Phillips Petroleum Company Australia Pty Ltd (Phillips) initiated the production of a Public Environment Report (PER) for an expanded LNG facility on Wickham Point of up to 10 MTPA production capacity. The PER was subsequently released in March 2002 for a 4-week public comment period. As with the previously approved 3 MTPA facility, the proposed 10 MTPA project involved construction and operation of the following major components:

• an LNG plant utilising the Phillips’ Optimised Cascade LNG Process which comprises: − gas processing facilities to remove impurities and refrigerate the natural gas; − product storage tanks; − plant infrastructure and utilities;

• a loading jetty on the west side of Wickham Point in Middle Arm of Darwin Harbour to transfer product to tankers for shipping to market;

• a construction dock on the north-east side of Wickham Point in East Arm of Darwin Harbour for transfer of building materials and heavy equipment; and

• a number of large ships to transport LNG from Wickham Point to global markets.

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The project comprised the same major components as proposed for the previously approved 3 MTPA Project, (except for the Pipeline) but differed principally in the capacity of the LNG plant and its layout on Wickham Point (shown in Figure 1). The access road, which will be constructed by the NT Government, has been relocated slightly and incorporated into a major arterial transport corridor originally proposed for construction by the NT Government in the Darwin Regional Land Use Structure Plan 1990. The main process flare has been relocated to the south of the process area also as a result of this transport corridor and has been redesigned from a single elevated flare to a multi-burner ground level configuration. The principal differences between the approved 3 MTPA plant layout shown on Figure 2 and the proposed new 10 MTPA expanded plant layout shown on Figure 1 are as follows: • the disturbed area envelope has increased in size and changed shape slightly, in regard to

the spill impoundment area, the main flare area, and the south eastern part of the plant site;

• instead of one 3 MTPA LNG process train, the plant will now comprise two LNG process trains totalling up to 10 MTPA. These trains will still use the Phillips’ Optimised Cascade LNG process as described in the Draft EIS. The increased plant capacity will result in increased volumes of atmospheric emissions and waste materials requiring disposal;

• instead of two LNG storage tanks there will be three larger tanks; • the new facility will not produce commercial quantities of other LPG products (i.e.

propane and butane) for export as originally proposed, as the feed stock gas will be processed offshore to remove LPGs. Any recoverable LPG products will be blended back into the finished LNG product. The only other saleable product will be small volumes of stabilised hydrocarbon condensate;

• the construction dock will now contain a dredged berthing pocket to –6 m AHD (Australian Height Datum) at the seaward end, instead of a gravel pad exposed at low tide;

• the length of the shiploading facility has been reduced by about 100 m to avoid the need for dredging in the turning basin;

• instead of an elevated main flare as originally proposed for the 3 MTPA plant, a large ground flare is proposed for the 10 MTPA plant;

• a metering facility has been located to the south of the main plant area where the metering and delivery of gas to domestic markets will occur; and

• the shore crossing for the offshore pipeline onto Wickham Point has been relocated 200 m south of the point originally identified.

Initial site preparation, involving the access road to Wickham Point being constructed by the NT Government, will be required in late-2002. The PER premised construction of the first phase (one process train up to 5 MTPA) proposed LNG facility anticipated to commence in late 2002 and be completed by early 2006. Construction of the second LNG process train, if additional gas supply arrangements can be secured, could commence in late 2003 and be completed in late 2006. The project was assessed under the NT Environmental Assessment Act (1982) and the transitional provisions of the Commonwealth Environment Protection (Impact of Proposals) Act 1971 (EPIP Act). The NT Minister for Lands, Planning and Environment released the Environment Assessment Report by the NT Office of Environment and Heritage in June 2002 (see Appendix A for the NT Government’s Environmental Assessment Report and Recommendations (EARR)).

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Figure 1 Plant layout for 3 MTPA LNG Plant Originally Approved in 1998

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Figure 2 Plant layout for 10 MTPA LNG Plant Approved in 2002

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The project was approved subject to the DLNG Project complying with 15 detailed requirements imposed by NTG (summarised in Table 1.1 on pages 12-17 of this document). Most of these requirements were similar to those previously applied to the 3 MTPA LNG Plant (in NT Assessment Report No. 24). However two new recommendations were added to address the potential need for a once-off discharge of hydrotest water to Darwin Harbour (Recommendation 6), and contingency options for the disposal of waste oil (Recommendation 8). Similarly, Environment Australia has made 15 recommendations that relate to the Darwin LNG Plant. These recommendations are also summarised in Table 1.1 and replace the recommendations made in EA’s February 1998 Environmental Assessment Report. (see Appendix B for the EA Environment Assessment & Approvals Branch’s Review and Assessment of Environmental Aspects, August 2002). 1.2.3 August 2002 Notice to Construct First LNG Train to 3.24 MTPA

Capacity In August 2002, Phillips Petroleum Company Australia Pty Ltd, advised the DIPE that its preliminary design for the first LNG Train was complete and that as a result of the uncertainty regarding access to the Greater Sunrise gas reserves, it was now the Proponent’s intention to construct that initial train to a nominal capacity of 3.24 million tonnes per annum (MTPA). This is smaller than the initial 5 MTPA train premised to be constructed as the first phase of the recently approved (June 2002) 10 MTPA LNG facility. This Environmental ‘Notice to Construct’ describes the environmental effects associated with the design changes for this 3.24 MTPA LNG plant. These changes will result in lower net air emissions than an equivalent sized plant that would have used the technologies premised in the PER. Changes to the plant design are consistent with and progress the Proponent’s commitment to continue to evaluate alternative turbine combustion technology during the design phase of the project to further reduce atmospheric emissions and ensure that the best environmental and economic choices are made. The key modifications proposed for the 3.24 MTPA LNG plant (as compared with the 10 MTPA plant) are as follows: 1. Disturbance of only 66 ha (instead of 88.3 ha) of premises at Wickham Point. 2. Deferral of construction dock until a future train; 3. Use of more energy efficient turbines in the gas liquefaction process; 4. Addition of a Reverse Osmosis/Demineralisation water purification unit; 5. Consumption of condensate as fuel for the acid gas oxidation unit; and 6. Adoption of Best Available Technology for wastewater treatment. The key environmental benefits resulting from the above modifications are: 1. Reduced area of habitat disturbance within the approved disturbance envelope for the

10 MTPA plant; 2. Deferral of the construction dock means that there will be no dredging required for an

access channel, there will be a substantial reduction in area of mangroves removed, and a native fauna corridor will be maintained along the northern side of the plant;

3. The use of more energy efficient turbines will mean that less fuel will be consumed per unit of LNG produced and therefore reduce the estimated emissions of greenhouse gases (GHG) by 22.4% per MTPA of LNG production from those

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premised for the 3 MTPA plant approved in 1998 and by 3.6% per MTPA from the 10 MTPA plant approved in 2002. In addition non-GHG such as NOx , CO, PM and SO2 are also reduced ;

4. Consumption of expected normal production volumes of condensate as fuel on site means the loading and transport condensate will be substantially reduced, thereby reducing the risks associated with handling of this flammable product; and

5. The adoption of advanced wastewater treatment technologies means that the concentrations of oil and nutrients in wastewater requiring disposal to irrigation or to Darwin Harbour will be substantially reduced.

However, some of the above benefits come at a potential environmental cost. The “costs” are principally associated with the use of both the energy efficient turbines, and the advanced wastewater treatment systems. These costs are summarised below:

The new energy efficient turbines require reduced nitrogen concentration in the fuel gas. Therefore a nitrogen rejection unit will be incorporated into the liquefaction process, and rejected nitrogen will be vented to the atmosphere. As a result of lower nitrogen in the fuel, the turbines will operate at higher combustion temperatures and without mitigations would produce more NOx emissions per unit of production. However, mitigation of the increased NOx emissions to levels per MTPA at or below those premised in the PER is incorporated into the 3.24 MTPA plant design. The amount of NOx produced by the turbines will be reduced at least to limits (per MTPA) premised in the PER by lowering the temperature of combustion. This is achieved by injecting pure water into the turbines. This water is obtained by treating potable water supplied by PAWA to remove all minerals via a reverse osmosis demineralising unit. This unit will require an input of approximately 1500 tonnes/day of potable water, and will reject approximately 350 tonnes/day of clean blowdown water (comprising concentrated minerals), and the remainder (approximately 1150 tonnes/day will be injected to the turbines and be released to the atmosphere as water vapour (steam). Therefore, the environmental “cost” of using the new turbines to achieve a reduction in CO2 emissions, and reducing NOx emissions by at least by 20-25% and potentially up to 68% below levels comparable with those premised in the 10 MTPA plant PER, is the consumption of an additional 1500 tonnes/day of potable water, and the disposal to Darwin Harbour of approximately 355 tonnes/day of clean blowdown water. The environmental “cost” of adopting advanced wastewater technology is that there will be a 25% increase in oily sludge to be disposed as a result of an increased efficiency of oil removal by the treatment process. The deferral of the building of the construction dock for Train 1 will result in more construction materials being transported to the site by truck

The above costs are considered to be of minor significance when compared to the benefits achievable in reduction of atmospheric emissions and wastewater contaminants. (NB: The environmental management procedures in this EMP reflect the changes to the approved project as a result of the proposed construction of the 3.24 MTPA LNG processing train).

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1.3 STRUCTURE OF EMP VOLUME I As described in Section 1.1, the framework for the overall DLNG Project EMP has been restructured into specific volumes to address each major stage of project development. This overview document is divided into five primary sections: 1. Introduction, background and summary of proponent commitments and Ministerial

approval conditions; 2. Framework for establishing Emergency Response Manuals; 3. Oil Spill Contingency Plans; 4. Corporate Relations Plan; and 5. Compliance Auditing and Reporting plan. A glossary and references are included at the conclusion of this document. 1.4 PURPOSE AND OBJECTIVES OF EMP The objective of the EMP is to establish management and monitoring plans which ensure that actual and potential impacts associated with the construction, operation and decommissioning phases of the LNG plant are minimised, and that compliance with all relevant environmental regulations is achieved. The specific objectives of the EMP are to provide a planned structure which will:

• ensure that construction activities are undertaken in an appropriate manner and that impacts on the environment are minimised and monitored;

• ensure that impacts associated with the operational phase of the development are minimised and monitored; and

• minimise the risk of potential effects from unexpected incidents, such as oil spills, and ensure that appropriate contingency plans are in place in the event of such incidents.

The EMP also identifies the timing and scope of individual components of the environmental management plan, and serves as a compliance document - recording the progress of management commitments and their conformity with requirements set by authorities and expectations of the public. An EMP is therefore a means of both documenting and auditing environmental management commitments made by the proponent. 1.5 HEALTH, ENVIRONMENT AND SAFETY MANAGEMENT Phillips and its subsidiaries address environmental management through a corporate Health, Environment and Safety (HES) Management System. The HES Management System helps to ensure that health, environment and safety are incorporated into every aspect of the company’s business.

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The HES Management System is comprised of four main components:

1. The HES Policy, which defines the company’s commitment to being a responsible corporate citizen;

2. The Process for Safety and Environmental Excellence (PSEE), which provides the structure for implementing the policy and identifies a progressive series of steps that lead to higher levels of performance;

3. Plans and Objectives, set by business units and staff to continuously improve HES performance; and

4. Measuring Progress, a rigorous review and auditing system that is designed to ensure that the policy is implemented and that all facilities are in compliance with applicable laws and regulations.

An integral element of the Process for Safety and Environmental Excellence is a continuous improvement loop. This is shown in Figure 3 on page 11. On August 30, 2002 Phillips Petroleum Company and Conoco Inc. merged to form ConocoPhillips. Phillips Petroleum Company Australia Pty Ltd, as a subsidiary of ConocoPhillips, will develop a health, safety and environmental policy and process likely to be similar but not identical to that presented herein. 1.6 PROPONENT’S CORPORATE HES POLICY Phillips Petroleum Company recognises that Health, Environment and Safety (HES) is inextricably linked to financial and operating performance, and has a proven commitment to developing and implementing a management system that integrates HES into every aspect of business. This HES Management System is part of a larger systems-based approach to achieving operating excellence throughout the company. The company’s Health, Environment and Safety Policy, as adopted by the Australasia Division, is summarised below: “Phillips Petroleum Company Australasia Division will conduct all operations in a manner that protects human safety and health, the environment and company property, while complying with all applicable laws and regulations. Moreover, the company will strive for continuous improvement in these areas. Health, Environment and Safety protection is a line responsibility that extends to all levels of management. All employees and contractors are to perform their work in accordance with this policy. This policy is carried out through the following practices: • Seeking continual improvement of the health, environmental and safety management

systems through the use of the Process for Safety and Environmental Excellence,

• Providing the necessary resources,

• Informing employees of this policy and providing them the training to safely perform their individual responsibilities and duties safely and in an environmentally responsible manner,

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• Providing relevant safety and health information to contractors and requiring them to provide proper training to perform their individual responsibilities safely and in an environmentally responsible manner,

• Incorporating health, environment and safety requirements at the design phase and in operations,

• Reviewing and reporting the performance of the company’s operations and facilities on a periodic basis,

• Conducting industrial hygiene, safety and environmental reviews of existing facilities and properties for acquisition or sale,

• Establishing and maintaining communications on health, environment and safety issues with our communities, as well as with concerned groups and regulatory agencies,

• Providing appropriate equipment for the safe performance of the work,

• Establishing, maintaining, and reviewing with our communities, as well as with concerned groups, Emergency Readiness Plans to minimise health impacts, injuries, damage to environment, and/or property loss to the community or company, and

• Encouraging and supporting sound research and engineering to produce technology and products consistent with Phillips Petroleum’s objectives.

Any employee who knowingly violates applicable health, environment and safety policies, laws and/or regulations will be subject to disciplinary action, up to and including discharge. The complete commitment of all employees and contractor personnel is essential to accomplishing Phillips Petroleum Company’s Australasia Division’s goal of being a safe and environmentally responsible operator.

Stephen R. Brand President Phillips Australasia Division

1.7 PROPONENT’S COMMITMENTS Phillips Petroleum Company Australia Pty Ltd is committed to a broad range of environmental management commitments to ensure that the DLNG Project is constructed and operated in a responsible manner. Table 1.2 (pages 18-32) summarises DLNG Project’s consolidated commitments, as documented by the Office and Environment & Heritage’s Environmental Assessment Report 39 and Environment Australia’s August 2002 Review and Assessment of Environmental Aspects Report, prepared by its Environment Assessment & Approvals Branch. For each recommendation, DLNG Project has identified which volume of the EMP (I through to IV) will address the related action items in detail.

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Figure 3 Phillips’ Process for Safety and Environmental Excellence

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Darwin LNG Plant – Environmental Management Programme, Volume 1 00533-255-562/R907(M&C1629) : Revision 0, 4 October 2002 Page 12

Table 1.1 Summary of Recommendations from 2002 DIPE Assessment Report 39 and EA Review and Assessment Report (August 2002) DIPE No. Recommendation EA

No. Recommendation

1 The proponent shall ensure that the proposal is implemented in accordance with the environmental commitments and safeguards: • identified in the Darwin 10 MTPA Facility Public Environmental

Report and as modified in the proponent’s response to issues raised by the public and NT Government agencies that reviewed the PER; and

• as recommended in this Assessment Report (No. 39) which includes relevant recommendations from the previous Assessment Report (No. 24).

13

14

The proposal shall be implemented consistent with the commitments and undertakings provided by the proponent in the draft Public Environment Report (January 2002), final Public Environment Report (March 2002) and the proponents response to issues raised by the public and NT Government agencies that reviewed the Public Environment Report. Additional recommendations made by the Northern Territory Government following assessment under the Northern Territory Environmental Assessment Act 1982 shall be undertaken.

2 If expansion of the 10 MTPA plant is proposed, the revised project design shall be submitted to the NT Government for further assessment under the NT Environmental Assessment Act 1982.

3 The proponent shall quantify the major emission sources during commissioning of the project, by periodic emission testing programs. Dependent on the results of this verification process, the proponent will establish a monitoring system for oxides of nitrogen (NOx) from key emission sources at the facility and shall verify that standards contained in the Ambient Air Quality National Environment Protection Measure (NEPM) are not exceeded. Procedures for monitoring and reporting shall be developed in consultation with the Office of Environment and Heritage and shall meet relevant NEPM requirements and Australian Standards.

1 The Operations Environmental Management Plan shall include a section on periodic emission testing programs to quantify the major emission sources. Dependent on the results of this verification process, the proponent will establish a monitoring system for oxides of nitrogen (NOx) from key emission sources at the facility and shall verify that standards contained in the National Environment Protection Measure for Ambient Air Quality are not exceeded. Procedures for monitoring and reporting shall be developed in consultation with the Northern Territory Office of Environment and Heritage and shall meet relevant NEPM requirements and Australian Standards. AGO to provide revised recommendation.

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Table 1.1 (continued) DIPE No. Recommendation EA

No. Recommendation

4 The proponent’s Environmental Management Program shall include a section specifically addressing commitments and strategies aimed at reducing greenhouse gas emissions. This shall include (for example) provisions for regular greenhouse gas audits, a process for continuous review of new technologies to identify opportunities to reduce emissions, and benchmarking against other LNG facilities with a view to achieving international best practice in terms of carbon dioxide emissions per unit of production. Opportunities for offsetting greenhouse gas emissions, including support for relevant research, shall also be addressed.

2 The Operations Environmental Management Plan shall include a greenhouse strategy section specifically addressing: • the commitments and strategies taken to reduce greenhouse gas emissions; • consideration of alternatives to the release of greenhouse gas emissions into

the atmosphere; • provisions for regular greenhouse gas audits; • a process for continuous review of new technologies to identify

opportunities to reduce emissions; and • benchmarking against other LNG facilities with a view to achieving

international best practice in terms of CO2 emissions per unit of production. In developing its greenhouse gas strategy, the proponent shall consult

with the Greenhouse Unit of the NT Office of Environment and Heritage, and the strategy shall be provided to Environment Australia.

3 The proponent shall continually assess higher efficiency turbines as part of the design of the facility. The proponent shall also include, as part of the Construction and Operational Environmental Management Plans details on the process and timeframe by which the selection of higher efficiency turbines will be considered and potentially incorporated into the project. If incorporated, the proponent shall report on the impact of high efficiency turbines on reducing or offsetting the greenhouse gas emissions of the project.

5 This Assessment Report acknowledges the negotiations between the proponent, the Civil Aviation Safety Authority (CASA), Darwin Airport authorities and other relevant agencies to resolve outstanding concerns regarding potential impacts from flaring on aviation. If continuing studies indicate a potential significant risk to aviation, further analysis of hazards and risks to aircraft from flaring shall be required prior to the proponent’s final decisions on the design and operation of flares.

9 Negotiations between the proponent, Darwin Airport authorities, the Civil Aviation Authority and other relevant authorities to resolve outstanding concerns in regard to safety interactions between flaring and aviation are noted. If continuing studies indicate a potential significant risk to aviation, further analysis of hazards and risks to aircraft from flaring shall be required prior to a final decision on the type or nature of flaring to be used.

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No. Recommendation

6 If chemical additives used in hydrotest water pose a risk of toxicity to marine life in the Harbour, the proponent will require a Waste Discharge Licence. The Licence will require the proponent to analyse the hydrotest formulation to be used (to assess the potential toxicity to marine biota) and to monitor the receiving water to ensure adequate dilution and dispersion to reduce toxicity to an acceptable level. Further, if there is a credible risk of toxicity in the discharge, the proponent will provide adequate notice to nearby aquaculturalists to allow them time to implement desired precautionary measures. (This will comprise an additional safeguard to protect stock at these facilities.)

5 The proponent shall investigate chemical additives used in hydrotest water. If chemical additives used in the hydrotest water pose a risk of toxicity to marine life in Darwin Harbour, the proponent shall obtain the necessary Northern Territory Government approvals.

7 Treatment and disposal (by irrigation) of wastewater will need to comply with the Guidelines for Sewerage Systems – Use of Reclaimed Water (ANZECC/ARMCANZ 2000) and Site Specific Type Approval by the NT Department of Health and Community Services (DHCS). This will require the proponent to • conduct a detailed assessment of areas proposed for treatment and

disposal using the DHCS Site Report template; • evaluate the site constraints in order to choose the most suitable

system for treatment and disposal of wastewater; and • submit the report to DHCS supporting an application for the Site

Specific Type Approval. • treatment and disposal systems must comply with the requirements

of the DHCS Code of Practice for Small On-site Sewage and Sullage Treatment Systems and the Disposal and Reuse of Sewage Effluent.

5 The proponent shall consult with relevant Northern Territory Government agencies on treatment and disposal methods of wastewater, in particular, disposal by on-site irrigation, with a view to avoiding direct discharge to the waters of Darwin Harbour. If direct discharges of wastewater are required, modelling of the effluent mixing zone shall be undertaken to the satisfaction of NT Government agencies to ensure that sufficient dilution will occur at the proposed discharge point to minimise impacts on nearby habitats.

8 The proponent will consult with Office of Environment and Heritage to develop preferred and contingency options for management and disposal of waste oil and will include these in its Environmental Management Program.

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No. Recommendation

9 The proponent’s Environmental Management Program shall contain a Dredge and Spoil Disposal Management Plan that evaluates options for dredging, excavation and spoil disposal and addresses potential environmental impacts. This Plan shall include proposed measures to ensure protection of the Channel Island coral assemblages. The Plan shall also include a “Reactive Monitoring Program” that implements baseline studies (to set environmental triggers for concern), turbidity plume monitoring, a reactive coral monitoring program (if required), and contingency measures to be implemented if environmental triggers are exceeded or if monitoring detects potentially unacceptable environmental impacts. Development of the Dredge and Spoil Disposal Management Plan shall be done in consultation with relevant NT Government agencies and shall be submitted to the NT Government for approval prior to commencement of dredging.

6 The Construction Environmental Management Plan shall include a Dredge and Spoil Disposal Management Plan that evaluates options for dredging, excavation and spoil disposal and addresses potential environmental impacts. The Plan shall include proposed measures to ensure protection of the Channel Island coral assemblages which are listed in the Register of the National Estate, implementation of baseline studies, turbidity plume monitoring, a reactive monitoring program (if required), and contingency measures to be implemented if monitoring indicates adverse impacts. Any proposal for sidecasting of spoil shall be subject to additional sedimentation and turbidity modelling and may require implementation of a reactive monitoring program to ensure that the coral assemblages of Channel Island are adequately protected. Development of the Plan shall be done in consultation with relevant NT Government agencies and Environment Australia.

10 An emergency management plan addressing LNG carrier operations at sea, in Darwin Harbour and at the loading jetty shall be developed in consultation with relevant authorities such as the Darwin Port Corporation and the Australian Maritime Safety Authority. The plan shall include • measures to ensure compliance with national and international safety

regimes; • reporting procedures and organisational responsibilities in the event

of incidents; • contingency measures to minimise risks to human safety and the

environment; • specification of adequate resources to be held on ship and at berth to

deal with credible contingencies; and • a communication strategy to ensure effective and efficient liaison

among shore-based and ship-based emergency response teams.

8 An emergency management plan addressing LNG carrier operations at sea, in Darwin Harbour and at the loading jetty shall be developed in consultation with relevant authorities such as the Darwin Port Corporation and Australia Maritime Safety Authority. The plan shall include matters such as measures to ensure compliance with national and international safety regimes, reporting procedures and organisational responsibilities in the event of incidents, control of incident responses, contingency measures to minimise risks to human safety and the environment, minimum resources to be held on ship and at berth to deal with credible contingencies, and interactions with shore based or other emergency response team.

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No. Recommendation

11 Oil spill contingency plans for the construction dock and product-loading jetty shall be prepared by the proponent, within the overall context of the Darwin Port Corporation’s Oil Spill Contingency Plan. The site-specific plan shall include • an assessment of potential risks of spills of credible volumes; • potential oil spill trajectories; • maps of priority areas for protection (including aquaculture

facilities); • details for deployment of equipment to protect priority areas, • demonstrated integration with the Darwin Port Corporation Plan; • inventory of equipment for control and clean-up (including materials

held at the jetty and/or construction dock for immediate clean-up of minor spills);

• strategies, actions and responsibilities for any clean-up; and • a training and exercise strategy that includes relevant NT

Government response personnel.

12 An oil spill contingency plan for the port facility shall be prepared by the proponent, within the overall context of the Darwin Port Corporation’s Oil Spill Contingency Plan. The site specific plan shall include an assessment of potential risks of spills and credible volumes, potential oil spill trajectories, maps of priority areas for protection including aquaculture facilities, deployment of equipment to protect priority areas, integration with the Darwin Port Corporation Plan, inventory of equipment to deal with control and clean-up (including with Northern Territory authorities).

12 The proponent’s Environmental Management Program shall include specific measures to minimise loss and disturbance to remaining mangrove and dry rainforest habitat at Wickham Point. This shall include measures to avoid unnecessary clearing and disturbance during construction, measures to monitor and control weed and feral animal incursions, and measures to minimise fire risks.

4 The proponent shall include, as part of the Construction and Operational Environmental Management Plans, specific measures to minimise loss and disturbance to remaining mangrove and dry rainforest habitat at Wickham Point as a result of the construction and operation of the proposed plant. This shall include measures to avoid unnecessary clearing and disturbance during construction, measures to monitor and control weed and feral animal incursions, and measures to minimise fire risks.

13 As part of the proponent’s Environmental Management Program, an Acid Sulfate Soil Management Plan shall be prepared in consultation with relevant NT Government agencies. Sampling and analysis of potential acid sulfate soils shall be conducted as part of preparing the Plan. The Plan shall include monitoring of leachate from any soil or spoil retention areas and reclamation areas, and contingency measures in the event leachate is found to be excessively acidic.

7 The proponent shall include, as part of the Construction and Operational Environmental Management Plans, an Acid Sulfate Soil Management Plan and Monitoring Program. This Plan shall include sampling and analysis of potential acid sulfate soils, monitoring of leachate from any soil or spoil retention areas and reclamation areas, and contingency measures in the event leachate is found to be excessively acidic.

1. INTRODUCTION



No. Recommendation

14 In preparing the Environmental Management Program (EMP), the proponent shall include any additional measures for environmental protection and monitoring contained in recommendations made by the Northern Territory and Commonwealth Governments with respect to the proposal. The EMP shall be referred to relevant NT agencies and Environment Australia for review prior to finalisation, after which it shall become a public document. The EMP shall form the basis for relevant approvals and licences issued under NT legislation.

11 The proponent shall prepare Environmental Management Plans covering all aspects of environmental management and monitoring for the design, construction and operation of the proposed LNG plant at Wickham Point. The EMPs shall include any additional measures for environmental protection and monitoring contained in recommendations made by the Commonwealth and Northern Territory Governments in respect to the proposal. The EMPs shall be referred to Environment Australia and relevant NT Government agencies for review, prior to finalisation. The final EMPs shall be made publicly available.

15 The proponent shall ensure that decommissioning is done according to the best environmental standards available at the time.

15 The proponent shall advise Environment Australia, in writing, of actions taken to implement those recommendations accepted by Government. This should occur at the final design stage of the onshore plant, and thereafter at yearly intervals, until all outstanding recommendations have been addressed to the satisfaction of Environment Australia.

10 The proponent shall establish a liaison committee to provide for consultation on issues affecting Aboriginal interests throughout the detailed design, construction and operational phases of the proposal.

1. INTRODUCTION


Table 1 .2 Summary of Environmental Management Commitments for the Darwin LNG Project

COMMITMENT / SAFEGUARD

RECOMMENDATION FROM:

Assessment Report 39

[Assessment Report 24]

VOLUME OF EMP WHICH ADDRESSES

COMMITMENT (I – IV)

PLANNING & FUTURE EXPANSION Proponent will liaise with DIPE regarding future management of northern tip of Wickham Point (Section 1861). IV Any proposed expansion beyond the 10 MTPA plant or changes to operations that substantially increase emissions (especially NOx) will require further assessment under the NT Environmental Assessment Act.

2 [3] IV

ATMOSPHERIC EMISSIONS Proponent will quantify major emission sources during commissioning, by emission testing programs; if required, monitoring will be done for NOx to ensure compliance with NEPM standards; procedures will be developed in consultation with OEH.

3 [13] IV

Acid gas incinerator, management of wastes by professional contractors and other measures will prevent production of off-site odours.

IV

To further reduce atmospheric emissions and ensure that the best environmental and economic choices are made, the proponent will continue to evaluate alternative turbine combustion technology during the design phase of the project.

I ∗

GREENHOUSE GAS EMISSIONS The project will incorporate a waste heat recovery system from the gas turbine exhaust and use it for various heating requirements. (This will mitigate the release of greenhouse gas emissions that would have been released if gas fired equipment were used to provide the same heating requirements.)

IV

A ship vapour recovery system will be used to minimise or eliminate flaring of gas generated during LNG tanker loading and resulting in greenhouse gas emissions.

IV

During design and construction phases, proponent will continue to evaluate offset options, including vegetation-related offsets and geological sequestration (= reinjection offshore) and options for reducing greenhouse gas emissions.

4 [14] IV

Consideration of vegetation-related offsets will include projects in East Timor and others specifically of benefit to the Northern Territory. For the latter, the proponent will work with the Greenhouse Unit of the NT OEH.

IV *

∗ Currently in progress.

1. INTRODUCTION


Table 1.2 (continued)







The EMP will contain a specific section on strategies to reduce greenhouse gas emissions, including provision for audits, a process of regular review of new technologies, benchmarking against other LNG facilities (to achieve international best practice), and consideration of offsets.

4 [14] IV *

The proponent will liaise with the NT OEH in developing its Greenhouse Strategy, and the strategy will be provided to Environment Australia.

4 [14] IV

As part of the proponent’s commitment to participate in the Commonwealth Government’s Greenhouse Challenge Program, the proponent will develop a detailed Cooperative Agreement with the Australian Greenhouse Office which will outline: • an inventory of GHG emissions from the facility; • an action plan to minimise emissions; • performance indicators to measure progress; and • a forecast of expected abatement of GHG emissions over a set time period.

IV

FLARING The proponent will continue to work with consultants, CASA and other relevant agencies to identify, quantify and mitigate any impacts to airspace from flaring.

5 [16] I *

TEMPORARY SANITATION FACILITIES (Construction Phase) The proponent, through its main contractor, will establish procedures for collection and off-site disposal of waste products, and methods will comply with regulations of the DHCS.

II

HYDROTEST WATER The proponent will further consider the option of using sea-water (instead of freshwater) if risks from corrosion can be sufficiently minimised and adequate cleaning tanks prior to commissioning proves feasible.

6 II

If hydrotest water will contain toxic additives, the proponent will obtain a Waste Discharge Licence which will require full analysis of the hydrotest water and environmental monitoring to ensure adequate dilution and dispersion reduce risks to marine biota to an acceptable level. Before discharging such hydrotest water, the proponent will provide adequate notice to nearby aquaculturists to allow time to implement desired precautionary measures.

II

_____________________ * Currently in progress.

1. INTRODUCTION









IRRIGATION WITH WASTEWATER & STORMWATER To minimise discharge of wastewater and stormwater to the Harbour, the proponent will treat this water and use it to irrigate vegetation on-site, except for contingent events (such as wet season saturation).

IV

Low volumes of treated sewage will be pumped to a sewage treatment plant and treated effluent will be routed to an irrigation system after dechlorination. Holding tanks for treated effluent will allow testing to ensure the water quality is suitable for irrigation.

IV

Treatment and disposal by irrigation of all wastewater will comply with relevant NT and Commonwealth guidelines for re-use of wastewater. This will require to proponent to do detailed site assessments and submit findings to DHCS for Site Specific Type Approval.

7 [8] IV

The proponent will liaise with DIPE, DHCS and other NT Government agencies to design the most environmentally-appropriate irrigation system for the site.

7 [8] IV *

The proponent will evaluate (during the design phase) the feasibility and benefit of using local hardwoods for landscaping and soaking up wastewater used for irrigation.

IV *

To avoid impacts on the ecological integrity of surrounding dry rainforest, treated effluent will not be used to irrigate this vegetation.

IV

DISCHARGE OF WASTEWATER & STORMWATER TO DARWIN HARBOUR The proponent has indicated that there will be no point-source discharge of wastewater to the Harbour from construction activities or temporary facilities during the construction phase.

II

Uncontaminated stormwater will be segregated from potentially contaminated streams and disposed of by direct discharge to adjacent waters. Stormwater collected within the process area will be routed to a drain sump and oily derivatives removed prior to discharge.

IV

____________________ * Currently in progress.

1. INTRODUCTION









Once the design of the wastewater treatment system is completed, the proponent will confirm with DIPE the conditions under which direct discharge to the Harbour may be done (in contingency situations). If such discharge is considered a risk to nearby aquaculturists, the proponent will model likely trajectories and liaise with these facilities to develop contingency plans to protect their operations. The proponent will need a Waste Discharge Licence to release treated effluent to the Harbour.

IV

POTENTIAL FOR RADIOACTIVE WASTE STREAMS Although levels of naturally occurring radioactive materials (NORMs) in the feed gas will be low, the proponent will comply with all applicable NT regulations and guidelines should there be any radioactive wastes requiring disposal.

IV

DISPOSAL OF SOLID & SEMI-LIQUID WASTES The proponent will actively pursue waste minimisation and recycling opportunities to reduce solid and semi-liquid waste streams where possible. An Operational Waste Management Plan, prepared as part of the EMP, will further detail the proponent’s approach to managing these wastes.

IV

Non-hazardous wastes (e.g. ceramic balls, biological sludge and domestic garbage) will be disposed of by waste management contractors and will meet requirements of OEH.

IV

Wastes not suitable for disposal at the Shoal Bay Waste Disposal Site (e.g. waste oils, biological sludge and spent solvents) will be disposed of by commercial waste management contractors. The proponent will review waste-tracking documentation to ensure these wastes are disposed in a manner approved by OEH.

IV

CONSTRUCTION WASTES Where practical, the proponent will use cleared terrestrial vegetation and/or mangroves for rehabilitation. Cleared vegetation will not be stockpiled on-site (to avoid creating breeding habitat for biting insects).

II

Stockpiled vegetation, beyond that which can be chipped for re-use onsite, will be disposed of by burning in accordance with appropriate permits. 1

II

To avoid land subsidence, geo-technical advice will be sought if vegetation will be left in place and covered with fill.

II

1 This commitment changed in accordance with recent discussions with DIPE and submitted “Application for an Environmental Protection Approval” (Exhibit1).

1. INTRODUCTION









Removal of domestic wastewater will be contracted to a local waste management company and the proponent will require waste tracking documentation to ensure disposal meets the requirements of OEH, DHCS and PAWA.

II

Waste oils will be collected and disposed of properly through a commercial waste management contractor.

II

A temporary area will be established for stockpiling scrap metal, which will be collected for off-site recycling and/or disposal. Construction wastes will not be disposed of on-site.

II

A full description of the proponent’s plans for management of construction wastes will be included in the Construction Environmental Management Plan (as part of the EMP)

II

SPENT AMINE The plant design will facilitate collection and re-use of amine. If disposal is required, the proponent will include options for disposal in its Operational Waste Management Plan prepared as part of the EMP.

IV

CARBON BEDS (containing waste mercury) The proponent recognises that carbon beds containing mercury may not be suitable for disposal at any landfill site and will include options for treatment and disposal in its Operational Waste Management Plan.

IV

WASTE OIL (Operational Phase) The proponent will liaise with OEH to develop preferred and contingency plans for management of waste oil.

8 IV

DREDGING & DISPOSAL OF SPOIL The proponent will develop a Dredge and Spoil Management Plan as part of its EMP in consultation with the DPC, OEH and DBIRD (Fisheries). This Plan will include further characterisation of sea-bed sediments (to refine predictions about plumes) and a “Reactive Monitoring Program” (to detect and deal with unacceptably high turbidity from dredge-related activities). Monitoring will include ensuring the continued health of coral assemblages at Channel Island.

9 [6] III

1. INTRODUCTION









The proponent will need to apply for a Waste Discharge Licence for either side-casting spoil directly into the Harbour (if this activity is permitted) or discharge of decant water from land-based settlement ponds.

III

To avoid unacceptable cumulative impacts from discharge from both Wickham Point and East Arm Port (if dredging for these coincide) and to facilitate use of suitable spoil from the LNG project for the Port project, the proponent will liase with the DPC and OEH to coordinate their dredging schedules and monitoring programs.

III

The proponent will liaise with OEH to ensure that dredging works are done in an acceptable manner and that excess dredge material will be managed and disposed of to the satisfaction of OEH.

III

The proponent will liaise with nearby aquaculturalists to avoid unacceptable impacts on their operations from plumes generated from dredging activities.

III

SHIPPING To minimise the risk of grounding or collision, shipping movements will be coordinated through the DPC, including escort by tugs to and from the loading jetty and with the RAN. A 500 m “moving exclusion zone” around each ship is proposed. The navigational risk associated with shoals of Charles Point Patches will be addressed by continued liaison between the proponent and the DPC.

IV

To minimise the potential for direct or indirect disturbance to dugongs off Wickham Point, LNG tanker speeds will be kept at an appropriately low level within the Harbour, as agreed with NT Government authorities.

IV

To minimise risks to dugongs and sea turtles that forage around Channel Island, LNG shipping operations will remain away from the Channel Island area.

IV

To minimise potential damage from grounding, collision or other incident, the proponent will prepare, maintain, test and review Emergency Response Plans, LNG Accident Response Plans and Oil Spill Contingency Plans (prepared in consultation with the DPC, DIPE [Marine Branch] and other relevant NT Government agencies).

10 [18] & 11 [19] IV

LNG carriers will be designed, constructed, maintained and operated in compliance with international standards and subject to regular survey and inspection by vessel Classification Societies.

IV

Recognised international guidelines will be used in the design and construction of the LNG jetty and in the establishment of operating procedures for ship manoeuvres and cargo transfer.

III, IV

1. INTRODUCTION









RESTRICTED PUBLIC ACCESS Recreational fishing off the northern tip of Wickham Point will not be affected by the LNG plant: the only restrictions will be adjacent to the loading jetty and construction dock, both of which are well away from the area of greatest fishing interest. There will be no restriction of access to landing in the region of the old leprosarium.

IV

HAZARD & RISK ANALYSIS During the detailed design phase, the proponent will complete the following: • a final HAZOP (Hazard & Operability) Study, to identify all potential scenarios involving failure of

valves/controls and other upset conditions; • a final QRA (Quantitative Risk Assessment), to identify, assess, evaluate and manage all potential risks

associated with the project; and • a detailed Safety Report for the LNG plant, in accordance with relevant Worksafe Australia Standards and

prepared on the basis of the HAZOP and QRA studies above.

IV

All practicable measures to prevent hazardous incidents and to mitigate their consequences will be adopted.

IV

TRANSPORT OF HAZARDOUS MATERIALS The proponent will do an assessment of hazardous wastes transported to and from the facility and prepare contingency plans to deal with any accidental spillage.

II, IV

INCREASED ROAD TRAFFIC (Construction Phase) Use of the road network for transport of materials and equipment will be in keeping with DIPE regulations and is not expected to have significant impact on commuter traffic.

II

Potential road damage from the transport of heavy equipment will be avoided or minimised through use of barges to the construction dock.

II

SAFETY REPORT The proponent will consult with relevant NT Government agencies (during the detailed design phase) during development of a comprehensive Safety Report that meets the requirements of the National Code of Practice for Major Hazard Facilities.

IV

1. INTRODUCTION









CLEARING OF VEGETATION Clearing of vegetation will be staged to meet the minimal requirements of constructing and operating the plant. II The proponent’s EMP will include measures aimed specifically at minimising loss and disturbance to remaining dry rainforest and mangrove habitat at Wickham Point, including measures to monitor and control weed and feral animal incursions, and measures to minimise fire risks.

12 [11] II, IV

SELECTION OF DRY RAINFOREST OFFSET AREA(S) The proponent will continue to liaise with DIPE to identify an acceptable dry rainforest mitigation strategy, including identification of an appropriate area (size and location).

IV ∗

MONITORING OF MANGROVES Monitoring of mangroves adjacent to the facility will be done by the proponent. The proponent will liaise with DIPE and NTU to ensure that current and appropriate methodology (for the measurement of productivity is used.

II

FAUNA CORRIDORS If required by DIPE, the proponent will mitigate the potential obstacle the construction groyne might pose to faunal movements, by constructing earth ramps.

II

MARINE BIOTA The proponent will mitigate risk to marine biota by minimising the discharge of potential contaminants into the Harbour and by enduring that discharges comply with relevant guidelines of the National Water Quality Management Strategy Guidelines and with all requirements of any Waste Discharge Licences for the project.

IV

FIRE, WEEDS & FERAL PESTS In consultation with DIPE, the proponent will produce and implement a comprehensive weed management plan prior to construction of the facility.

II

All activities will fully comply with requirements of the Weeds Management Act. II, IV A Site Management Plan will include provisions for • cleaning and inspection of construction equipment prior to deployment on site; • monitoring for introductions (of weeds and feral pests) and their subsequent removal; and • fire prevention and control.

II


1. INTRODUCTION









EXOTIC MARINE PESTS All shipping under control of the proponent will comply with the Australian regulations for the management of ballast water and general AQIS guidelines to ensure no ballast water exchange occurs within or near Darwin Harbour.

IV

The proponent will liaise with DBIRD regarding the exotic marine pests monitoring program and mitigation of potential impacts from vessels servicing the facility.

IV

NOISE In the event that pile-driving is considered necessary, the proponent will model potential noise impacts on the residents of Darwin and Palmerston. If findings indicate a significant potential for disturbance, a Noise Management Plan will be prepared, in consultation with OEH and implemented by the proponent.

II

In the event that explosives are required (e.g. to prepare site for construction), noise reduction measures, such as the use of weighted blankets, will be adopted and in accordance with appropriate permits 2.

II

A detailed modelling study will be done after completion of the design phase to refine preliminary predictions of noise generation.

IV

To minimise risk of disturbance to the public, construction work will be done during daylight hours where practicable, when background levels of noise at the nearest populated areas will be greatest. Some activities, such as hydrotesting, may be required outside of daylight hours. 2

II

The proponent will ensure that noise during construction and operation of the plant will be managed to the satisfaction of OEH and comply with the Waste Management and Pollution Control (Environmental Noise) Regulations (when these come into effect).

II

2 This commitment changed in accordance with recent discussions with DIPE and submitted “Application for an Environmental Protection Approval” (Exhibit1).

1. INTRODUCTION









BITING INSECTS To avoid creating mosquito breeding areas, the proponent will comply with the NT Government’s guidelines “Construction Practice near Tidal Areas in the Northern Territory – Guidelines to Prevent Mosquito Breeding” (Whelan 1988).

II, IV

The proponent will prepare a detailed Biting Insects Management Plan to comply with requirements of the DHCS and to include in the final EMP.

II, IV

Personal protection of employees from biting midges will be employed and induction training implemented to ensure that the problem is managed in accordance with recommendations by DHCS, and the proponent’s approach will be detailed in the EMP.

II, IV

RADIATION Although the occupational risk from radiation is considered to be low, the proponent will develop procedures for protecting personnel from naturally occurring radioactive materials (NORM) that may be associated with the LNG feed gas (e.g. during plant shutdown and maintenance).

IV

When final equipment selection is done (during the design phase), any apparatus that is likely to contain radiation sources and/or irradiating equipment will be identified, and operation of this equipment will comply with provisions of the NT Radiation (Safety Control) Act.

IV

LIGHT EMISSION (at night) To avoid unacceptable impacts, the proponent will investigate (during the design phase) opportunities to minimise light emission at night.

IV

CONSTRUCTION WORKFORCE The proponent will commission a skills audit of the Darwin region to update their information on availability of skilled construction workers in the local labour market.

II

1. INTRODUCTION









DISCOVERY OF ARCHAEOLOGICAL/HERITAGE SITES & ARTEFACTS Five “highly significant” prehistoric middens (MA12, MA 13, MA 15, MA 18 AND MA 22) within or adjacent to the development footprint will be protected by erecting fencing around it and prohibiting entry and heavy machinery access to within 20 m.

II

For Sites MA 14, MA 16, MA 19 and MA 21, the proponent will obtain a permit to remove the middens, under Section 29 of the Heritage Conservation Act.

II

Newly discovered Site MH 4 is also likely to be subject to an application for disturbance and is currently the subject of further investigation in cooperation with the NT Heritage Conservation Branch (of OEH).

II ∗

The proponent will continue to work with OEH to establish a comprehensive procedure for the discovery of archaeological/historic sites, which will be completed by the proponent during development of the Construction EMP and endorsed by OEH before construction begins.

II

The proponent will continue to work with OEH to establish an Archaeological Sites Register for Wickham Point. II The proponent supports a proposal by OEH to have an archaeologist on-site during initial land clearing, or alternatively be on alert to enable a rapid response and assessment should any additional sites or objects be discovered during clearing activities.

II

To comply with the Heritage Conservation Act, the proponent will inform OEH of any new archaeological sites or features discovered prior to or during the construction and operational phases of the project.

II

On discovery of new archaeological sites or objects, vegetation clearing and other threatening activity will cease in the area of the site until OEH has a chance to inspect the site and advise on when/how the threatening activity can recommence.

II


1. INTRODUCTION









ABORIGINAL SACRED SITES The proponent will consult with AAPA and confirm that no sacred sites or burial sites will be affected by the proposed expansion to a 10 MTPA facility and will continue to liaise with this agency on an ongoing basis prior to and during the construction phase.

II

A current Authority Certificate will be obtained from AAPA prior to commencement of any on-site works.

II

The proponent will establish a “Heritage Issues Committee,” comprising representatives from OEH, AAPA and the Larrakia Association, to act as an advisory body for procedures regarding sacred sites and burial sites on Wickham Point.

II

EROSION & CONTROL OF SEDIMENTATION The proponent will submit, as part of their EMP, a draft Erosion and Sedimentation Control Plan to DIPE for approval prior to any construction works. This Plan will confirm key drainage flows across the site and specify a range of management measures to minimise erosion and siltation of the surrounding environment during plant construction and operation.

II

ACID SULFATE SOILS The proponent will prepare an Acid Sulfate Soil Management Plan to cover areas within the footprint of the 10 MTPA plant. The Plan will include ground-truthing to confirm areas on-site that may be at risk from acid sulfate soil characteristics and procedures to be adhered to by the construction contractor.

13 [7] II

The Acid Sulfate Soil Management Plan will include monitoring of leachate from any soil or spoil retention areas and reclamation areas, and contingency measures in the event leachate is found to be unacceptably acidic. The Plan will be submitted to DIPE for review and endorsement prior to the commencement of construction.

13 [7] II

1. INTRODUCTION









FUEL STORAGE Fuel storage at the facility will fully comply with AS 1940 (1993) requirements for “The storage and handling of flammable and combustible liquids” on-site, including adequacy of bunds to fully contain the largest potential spill (and water from a 24-hr rainfall event), properly-sited and maintained sumps, synthetic liners under tanks and drums, and a comprehensive inspection and emergency response systems.

II, IV

SUSTAINABILITY The proponent’s EMP will address sustainability issues in a “triple bottom line” approach, integrating environmental, social/cultural and economic factors. These factors will become “Key Result Areas,” with “Key Performance Indicators” determined for each area.

IV

REVISED/ FINAL ENVIRONMENTAL MANAGEMENT PROGRAM The proponent will prepare an LNG Plant Environmental Management Plan that will include specific management and monitoring actions to be implemented by the proponent to achieve sound environmental management of the plant site and will build on prior commitments made for the 3 MTPA facility. Potential impacts and associated mitigation strategies will include all phases of the plant’s life.

I-IV

The final EMP will be based on all matters involving regulatory compliance as well as corporate requirements to ensure the facility has an appropriate and effective Health, Safety and Environmental Management System.

14 [2] I-IV

Final plans to be integrated into the EMP will incorporate consideration of the additional level of risk associated with the expanded project and advice from the NT Government and Environment Australia.

14[2] IV

The EMP will be referred to relevant NT agencies and Environment Australia for review prior to finalisation, after which it will become a public document.

14[2] I-IV

1. INTRODUCTION









EMERGENCY RESPONSE PLANS Emergency Response Manuals The proponent will prepare emergency response manuals to cover the conceivable emergency situations at the plant and marine terminal, including situations off-site that could impact these facilities. The proponent will liaise with appropriate civil and port authorities to develop an emergency plan for the entire facility, to assist in continual review of the plan and procedures, to plan and run joint training and emergency exercises, and to develop effective and efficient communications during an emergency.

[15] II-IV

Cyclone Response Procedures To ensure a well-defined procedure is in place for safety shutdown and to secure the facility, the proponent will develop a cyclone contingency plan in consultation with the Darwin Port Corporation, NT Emergency Services and other government agencies involved in emergency management for the Darwin, Palmerston and Litchfield region. This plan will mitigate risk to employees, the general public and the facility, and the infrastructure at the plant will be designed to minimise the risk of significant damage from cyclones.

IV

When a cyclone is imminent, the plant will be shutdown and hydrocarbon inventory will be minimised. IV CORPORATE RELATIONS MANAGEMENT PLAN The proponent’s Corporate Relations Management Plan will establish the following: • a Corporate Relations Manager and Department; • a Public and Community Relations Program; • a Larrakia Liaison Committee; • a CASA/Air Service Australia Liaison Link; and • an internet web site.

I

COMPLIANCE AUDITING & REPORTING The proponent will be responsible for regular audits and reviews of the facility’s environmental and safety management, including both on-site auditing and review of performance reports.

I-IV

Additional inspections will be done in the event of significant environmental incidents, in conjunction with relevant government authorities.

I-IV

The proponent will meet requirements for any additional monitoring and reporting under the Waste Management and Pollution Control Act.

I-IV

1. INTRODUCTION









The proponent will produce an annual audit report to DBIRD, DIPE and Environment Australia (as required) and have a triennial review of the EMP.

I-IV

The proponent will do regular audits of its Environmental Management System, including assessment of the objectives, organisational structure, responsibilities, procedures, processes and resources available at the site.

I-IV

MONITORING COMMITMENTS For the 10 MTPA project, the proponent will build on the following monitoring commitments made for the 3 MTPA plant: • abundance of weeds and feral animals in undisturbed areas of Wickham Point; • abundance of biting insects within the plant site; • effects of dredging on the coral communities of Channel Island and northeast Wickham Point; • productivity of mangroves adjacent to the plant site; • quantity, quality and methods of disposal of construction and operational wastes; • confirmation of the quantity and quality of atmospheric emissions; • volumes and quality of wastewater discharges, including effluent dispersion studies; • concentrations of heavy metals, TBT and total petroleum hydrocarbons (TPH) in the marine sediments and selected marine

biota in the vicinity of the jetty and construction dock ; and • contributing to monitoring programs for introduced noxious marine pests.

I-IV

DECOMMISSIONING At the end of the project life (estimated at 20-25 years), the plant will be decommissioned in accordance with the best environmental standards applicable at the time.

20 [24] IV

Plant equipment and piping will be purged of hydrocarbons, and plant and office equipment will be sold or disassembled and sold as scrap, or disposed of in accordance with regulatory guidelines. Regulatory guidelines will also be followed for dismantling of the construction dock and product-loading jetty.

IV

The proponent will rehabilitate the site in consultation with the NT Government, if the site is not sold and will not be used for other purposes.

IV


2. EMERGENCY RESPONSE MANUALS DLNG Project will prepare a series of emergency response manuals for the plant and marine terminal to cover the conceivable emergency situations that could occur, as appropriate for both construction and operation phases. These manuals (plans) will not only address situations that occur within the operating facilities, it will also address those situations offsite that could impact these facilities. 2.1 CONSTRUCTION PHASE For the construction phase of the plant Bechtel has prepared comprehensive procedures for response to a variety of emergency situations. The “Emergency Response” plan can be found as Appendix B in accompanying Volume II – Construction Phase EMP. 2.2 OPERATIONS PHASE It is DLNG Project’s intent to liaise with the appropriate civil and port authorities in development of the overall facility emergency plan. This external liaison will facilitate the development and continual review of the plan and procedures, provide for joint participation in training and emergency exercises, and develop effective and rapid communications and response in an emergency.

The Emergency Response Manuals will be supported by the following additional studies to be undertaken during the detailed engineering phase of the project:

• a final HAZOP (Hazard and Operability) Study, to identify all potential scenarios arising from the failure of valves and controls or other upset conditions;

• a final QRA (Quantitative Risk Assessment), to identify, assess, evaluate and manage all potential risks associated with the project; and

• a detailed Safety Report for the LNG plant, in accordance with relevant Worksafe Australia Standards and prepared on the basis of the HAZOP and QRA studies outlined above.

Plant Accident Response

A site emergency plan will be produced to cover conceivable accident situations. The plan will clearly describe the emergency organisation of personnel. The responsibility for deciding when to implement an emergency plan will rest with the site manager, and a key dedicated person (probably the shift supervisor or equivalent) will be designated to coordinate on-site actions. The emergency plan will be supported by emergency response manuals, relevant sections of which will be available to, and required reading for, all site personnel needing to work in hazardous plant areas, especially those likely to be directly involved in emergency response. The manuals will set down the procedures needed to implement the relevant part(s) of the emergency plan, and will be designed to provide instructions and advice to personnel involved in the response to an emergency on the actions to be taken. Personnel training and preparation for contingency scenarios will remain a high priority during the life of the project.

2. INTRODUCTION


LNG Carrier Accident Response

Planning for emergencies on LNG carriers will be based on an understanding of the types of accident that could occur and their possible consequences, together with an effective system of communication. Written procedures will be developed in liaison with the Darwin Port Corporation (DPC). Both the NT Marine Oil Pollution Plan (NT Coastal Waters) and the National Plan to Combat Pollution of the Sea by Oil (NATPLAN-Commonwealth Waters) would be applicable to LNG carrier accident responses at sea. In Darwin Harbour the relevant plan is the Darwin Harbour Oil Spill Contingency Plan (see Section 3, below). As with the on-site plan, ship emergency procedures will be reinforced by training and exercises, and will be continually reviewed and updated in consultation with the Darwin Port Corporation. Emergency Response Management

Emergency response management will be provided by a small team of senior managers (the control committee) who in turn will direct all response activities through the emergency response unit, plant security, communications, public relations, safety and environmental affairs, and material procurement departments. Each of these departments will have specific responsibilities to perform in the event of an emergency.


3. OIL SPILL CONTINGENCY PLANS A series of Oil Spill Contingency Plans (OSCPs) will be prepared by DLNG Project to enable effective response during both the construction phase and the operation phase of the project. During the construction phase, there is potential for spillage to land or water as a result of construction activities. During operations, there is potential for spillage in the harbour as a result of LNG carrier accidents or spillages at the loading jetty. The DPC has legal jurisdiction for dealing with oil spills in Darwin Harbour, and has developed a detailed Oil Spill Contingency Plan (OSCP) as part of the National Plan to Combat Pollution of the Sea by Oil (NATPLAN). A broader OSCP is also currently being developed for the whole of the NT, which is currently being considered by the NT (National Plan) Marine Pollution Management Committee prior to its anticipated finalisation in late 2002. The Darwin Port Corporation OSCP covers all areas of the port area, including the waters adjacent to the proposed LNG plant. As such, the DLNG Project OSCP for the harbour will be integrated into the existing OSCP. A supplementary plan, specific to the LNG plant, will be developed in consultation with the DPC and other relevant authorities. This plan will detail the organisational responsibilities, actions, reporting requirements and resources to ensure effective and timely management of an oil spill for operations in the Darwin Harbour area. The plan will interface with the DLNG Project Emergency Response Plan. The OSCP developed for the construction phase of the project can be found as Appendix C in accompanying Volume II – Construction Phase EMP.


4. CORPORATE RELATIONS PLAN 4.1 INTRODUCTION Phillips is committed to being recognised as a good corporate citizen and has incorporated appropriate practices into its HES policy to enable it to achieve this goal. Therefore, DLNG Project has developed a Corporate Relations Plan to ensure that the local community is informed about proposed operations and that key stakeholders have ready access to relevant information and appropriate DLNG Project personnel. DLNG Project proposes to manage corporate relations for this project by establishing the following:

• Corporate Relations Manager and Department;

• Larrakia Liaison Committee;

• Stakeholder Liaison Committee;

• Heritage Issues Committee;

• Darwin Airport Link;

• Public and Community Relations Programme; and

• internet web site. 4.2 CORPORATE RELATIONS MANAGER A manager will be employed by Phillips in Darwin to manage corporate relations with key stakeholders and the community at large. 4.3 LARRAKIA LIAISON COMMITTEE Phillips Petroleum Company Australia Pty Ltd has been active in liaising with local indigenous representatives since project investigations commenced in 1996. This will continue as a formalised process. An Aboriginal Liaison Committee will be established specifically to liaise with the Larrakia people regarding issues of significance to Aboriginal people along the proposed pipeline route, within Darwin Harbour and in relation to the Wickham Point plant site. 4.4 STAKEHOLDER LIAISON COMMITTEE DLNG Project is currently in the process of coordinating the establishment of a committee to liaise with all other stakeholders who may be affected by the construction programme and operations phase. DLNG Project is liaising with the NT government and the NT Chamber of Commerce and Industry regarding the establishment of this committee. Relevant NT government authorities will be represented on this committee plus private stakeholders such as recreational fishing and diving groups, ferry operators, charter boat operators and commercial fishing interests, aviation groups, etc.

4. CORPORATE RELATIONS PLAN


4.5 HERITAGE ISSUES ADVISORY COMMITTEE DLNG Project is coordinating the establishment of an Archaeological Advisory Committee to provide input into the ongoing protection of the indigenous heritage values on Wickham Point. It is proposed that this advisory committee will comprise representatives from Larrakia Nation, the Heritage Division of DIPE, AAPA and DLNG Project. 4.6 DARWIN AIRPORT LINK DLNG Project has an ongoing liaison link with CASA and Darwin International Airport to ensure satisfactory resolution of the heat impact from the ground flare on the southern approaches to Darwin airport. Phillips is in the process of preparing an application to Darwin International Airport Pty Ltd for the Secretary’s (Department of Transport and Regional Development) approval to conduct a controlled activity. 4.7 PUBLIC & COMMUNITY RELATIONS Information brochures will be produced for distribution to community groups, advertisements will be placed in local newspapers to inform the public of the occurrence of particular activities, and regular updates will be provided to keep the community informed of progress. 4.8 INTERNET WEB SITE An internet website will be established on which a summary of this EMP and subsequent volumes (II to IV) will be placed, together with information on where the full EMP can be viewed, current status of the project, and a register of auditable activities which have been complied with to date.


5. COMPLIANCE AUDITING AND REPORTING 5.1 OVERVIEW During the plant construction, commissioning and operations phases, DLNG Project will be responsible for the regular audit and review of the LNG facility’s environment and safety management. This will include both on-site auditing and review of performance reports. Additional onsite inspections and investigations will be undertaken in the event of significant safety or environmental incidents. Plant or Project Management personnel will participate in the audits, inspections and investigations. The proponent will also produce an annual audit report to DBIRD, DIPE and Environment Australia and have a triennial review of the EMP. DLNG Project management personnel will also be responsible for regular review of the environmental performance of the site and site personnel, and for tracking and reporting implementation of commitments made in the EMP. DLNG Project will incorporate into this program any compliance auditing and reporting associated with the licensing of the LNG Plant under the Waste Management and Pollution Control Act. In addition to internal reviews and audits conducted by DLNG or its parent organisations, independent reviews for compliance can be made by governmental regulatory compliance officers or other appropriate governmental officials at their discretion at any time. Table 5.1 presents a Compliance Audit Table which summarises for each government recommendation and proponent commitment the following information:

• the commitment or safeguard to be addressed by DLNG Project; • the NT Government and/or EA recommendation related to that commitment; • where the issue is addressed in this or subsequent volumes of the EMP; • a code for each action to be implemented by DLNG Project, identified according to the

phase of development (Construction, Dredging, or Operations). The action codes will be added to this table when the applicable EMP is issued;

• when the issue is to be addressed by; • to whose satisfaction the issue is to be addressed; and • the current status of compliance. In a report to be submitted to appropriate NTG authorities and EA 60 days after site construction commences and annually thereafter, DLNG Project will summarise activities and/or submit and/or reference previously submitted documents that demonstrate its compliance with the EMP requirements and its commitments for the reporting period. DLNG Project will seek acknowledgement from DIPE and EA that appropriate compliance with those commitments has been attained, at which time it will update Table 5.1 and make it public. This compliance status will be indicated in the last column of Table 5.1 using the following convention:

1 = full compliance achieved; 2 = incremental compliance with an ongoing objective achieved; 3 = compliance is not needed for this commitment at this time; and 4 = other (an explanation is required). For any issue that is noted as 4 (“other”), an explanation of the circumstances related to the issue and corrective actions taken or needed will be provided.

5. COMPLIANCE AUDITING AND REPORTING

Legend: Compliance Status 1 Full compliance achieved. 2 Incremental compliance with an ongoing objective achieved 3 Compliance is not needed for this commitment at this time 4 Other (an explanation is required) Darwin LNG Plant – Environmental Management Programme, Volume I 00533-255-562/R907(M&C1629) : Revision 0, 4 October 2002 Page 39

Table 5.1 Environmental Compliance and Audit Table for the Darwin LNG Project


RECOMMENDATIONS FROM:

DIPE Report 39 DLPE Report [24]

EA Report

VOLUME OF EMP WHICH

ADDRESSES COMMITMENT

(I – IV)

ACTION CODE

WHEN TO BE ADDRESSED

TO WHOSE SATISFACTION

COMPLIANCE STATUS

PROJECT IMPLEMENTATION The proposal shall be implemented consistent with the commitments and undertakings provided by the proponent in the draft Public Environment Report (January 2002), final Public Environment Report (March 2002) and the proponent’s response to issues raised by the public and NT Government agencies that reviewed the Public Environment Report.

13 I N/A Throughout life of project NT DIPE EA

Additional recommendations made by the Northern Territory Government following assessment under the Northern Territory Environmental Assessment Act 1982 shall be undertaken.

14 I N/A Throughout life of project NT DIPE EA

The proponent shall advise Environment Australia, in writing, of actions taken to implement those recommendations accepted by Government. This should occur at the final design stage of the onshore plant, and thereafter at yearly intervals, until all outstanding recommendations have been addressed to the satisfaction of Environment Australia.

15 I N/A Final design stage, thence annually

EA

PLANNING & FUTURE EXPANSION Proponent will liaise with DIPE regarding future management of northern tip of Wickham Point (Section 1861).

IV N/A Prior to submission of Development Permit Application

NT DIPE

Any proposed expansion beyond the 10 MTPA plant or changes to operations that substantially increase emissions (especially NOx) will require further assessment under the NT Environmental Assessment Act.

2 [3] IV N/A As decided by DLNG Project NT DIPE

ATMOSPHERIC EMISSIONS Proponent will quantify major emission sources during commissioning, by emission testing programs; if required, monitoring will be done for NOx to ensure compliance with NEPM standards; procedures will be developed in consultation with OEH.

3 [13] IV Pending During plant commissioning NT DIPE

The Operations Environmental Management Plan shall include a section on periodic emission testing programs to quantify the major emission sources. Dependent on the results of this verification process, the proponent will establish a monitoring system for oxides of nitrogen (NOx) from key emission sources at the facility and shall verify that standards contained in the National Environment Protection Measure for Ambient Air Quality are not exceeded.

1 Pending During plant commissioning NT DIPE EA

Acid gas incinerator, management of wastes by professional contractors and other measures will prevent production of off-site odours.

IV Pending Prior to commissioning of plant

NT DIPE

To further reduce atmospheric emissions and ensure that the best environmental and economic choices are made, the proponent will continue to evaluate alternative turbine combustion technology during the design phase of the project.

I Pending At detailed design phase prior to construction

NT DIPE

The proponent shall continually assess higher efficiency turbines as part of the design of the facility. The proponent shall also include, as part of the Construction and Operational Environmental Management Plans details on the process and timeframe by which the selection of higher efficiency turbines will be considered and potentially incorporated into the project. If incorporated, the proponent shall report on the impact of high efficiency turbines on reducing or offsetting the greenhouse gas emissions of the project.

3 Pending At detailed design phase prior to construction

NT DIPE EA

GREENHOUSE GAS EMISSIONS The project will incorporate a waste heat recovery system from the gas turbine exhaust and use it for various heating requirements. (This will mitigate the release of greenhouse gas emissions that would have been released if gas fired equipment were used to provide the same heating requirements.)

IV Pending At detailed design phase prior to construction

DIPE (Greenhouse), AGO

A ship vapour recovery system will be used to minimise or eliminate flaring of gas generated during LNG tanker loading and resulting in greenhouse gas emissions.

IV Pending At detailed design phase prior to construction



Table 5.1 Environmental Compliance and Audit Table for the Darwin LNG Project (cont’)





EA Report

VOLUME OF EMP WHICH


(I – IV)

ACTION CODE



COMPLIANCE STATUS

During design and construction phases, proponent will continue to evaluate offset options, including vegetation-related offsets and geological sequestration (= reinjection offshore) and options for reducing greenhouse gas emissions.

4 [14] IV Pending Throughout life of project DIPE (Greenhouse), AGO

Consideration of vegetation-related offsets will include projects in East Timor and others specifically of benefit to the Northern Territory. For the latter, the proponent will work with the Greenhouse Unit of the NT OEH.

IV Pending Throughout life of project DIPE (Greenhouse), AGO

The EMP will contain a specific section on strategies to reduce greenhouse gas emissions, including provision for audits, a process of regular review of new technologies, benchmarking against other LNG facilities (to achieve international best practice), and consideration of offsets.

4 [14] IV Pending Prior to plant commissioning DIPE (Greenhouse), AGO

The proponent will liaise with the NT OEH in developing its Greenhouse Strategy, and the strategy will be provided to Environment Australia.

4 [14] IV Pending Prior to plant commissioning DIPE (Greenhouse), AGO

As part of the proponent’s commitment to participate in the Commonwealth Government’s Greenhouse Challenge Program, the proponent will develop a detailed Cooperative Agreement with the Australian Greenhouse Office which will outline: • an inventory of GHG emissions from the facility; • an action plan to minimise emissions; • performance indicators to measure progress; and • a forecast of expected abatement of GHG emissions over a set time period.

IV Pending Prior to plant commissioning, and annual reporting thereafter


The Operations Environmental Management Plan shall include a greenhouse strategy section specifically addressing: • the commitments and strategies taken to reduce greenhouse gas emissions; • consideration of alternatives to the release of greenhouse gas emissions into the atmosphere; • provisions for regular greenhouse gas audits; • a process for continuous review of new technologies to identify opportunities to reduce emissions;

and • benchmarking against other LNG facilities with a view to achieving international best practice in

terms of CO2 emissions per unit of production.

2 IV Pending Prior to plant commissioning, and annual reporting thereafter


Opportunities for offsetting greenhouse gas emissions, such as through forestry plantations or support for relevant research, shall also be addressed and adopted if appropriate. The greenhouse strategy section shall be prepared to the satisfaction of Environment Australia.



The proponent shall undertake annual reporting of greenhouse gas emissions resulting from the proposal and submit these reports to the Australian Greenhouse Office through Environment Australia. The proponent is also encouraged to participate in the Greenhouse Challenge Program once commercial negotiations have been finalised.



FLARING This Assessment Report acknowledges the negotiations between the proponent, the Civil Aviation Safety Authority (CASA), Darwin Airport authorities and other relevant agencies to resolve outstanding concerns regarding potential impacts from flaring on aviation. If continuing studies indicate a potential significant risk to aviation, further analysis of hazards and risks to aircraft from flaring shall be required prior to the proponent’s final decisions on the design and operation of flares.

5 [16] I - At detailed design phase CASA, Air Services Australia

Negotiations between the proponent, Darwin Airport authorities, the Civil Aviation Authority and other relevant authorities to resolve outstanding concerns in regard to safety interactions between flaring and aviation are noted. If continuing studies indicate a potential significant risk to aviation, further analysis of hazards and risks to aircraft from flaring shall be required prior to a final decision on the type or nature of flaring to be used.

9 I - At detailed design phase CASA, Air Services Australia

TEMPORARY SANITATION FACILITIES (Construction Phase) The proponent, through its main contractor, will establish procedures for collection and off-site disposal of waste products, and methods will comply with regulations of the DHCS.

II CEMP 12, 9 Prior to commencement of construction

DHCS

HYDROTEST WATER







EA Report

VOLUME OF EMP WHICH


(I – IV)

ACTION CODE



COMPLIANCE STATUS

The proponent will further consider the option of using sea-water (instead of freshwater) if risks from corrosion can be sufficiently minimised and adequate cleaning tanks prior to commissioning proves feasible.

3 II CEMP 14.3 Prior to tank hydrotest activities (construction phase)

NT DIPE

If hydrotest water will contain toxic additives, the proponent will obtain a Waste Discharge Licence which will require full analysis of the hydrotest water and environmental monitoring to ensure adequate dilution and dispersion reduce risks to marine biota to an acceptable level. Before discharging such hydrotest water, the proponent will provide adequate notice to nearby aquaculturalists to allow time to implement desired precautionary measures.

6 II CEMP 14.1 CEMP 14.2

Prior to tank hydrotest activities (construction phase)

NT DIPE NT DBIRD (Fisheries)

The proponent shall investigate chemical additives used in hydrotest water. If chemical additives used in the hydrotest water pose a risk of toxicity to marine life in Darwin Harbour, the proponent shall obtain the necessary Northern Territory Government approvals.

5 II CEMP 14.1 Prior to tank hydrotest activities (construction phase)

NT DIPE EA

IRRIGATION WITH WASTEWATER & STORMWATER To minimise discharge of wastewater and stormwater to the Harbour, the proponent will treat this water and use it to irrigate vegetation on-site, except for contingent events (such as wet season saturation).

IV Pending During commissioning of plant

NT DIPE

Low volumes of treated sewage will be pumped to a sewage treatment plant and treated effluent will be routed to an irrigation system after dechlorination. Holding tanks for treated effluent will allow testing to ensure the water quality is suitable for irrigation.


NT DIPE

Treatment and disposal (by irrigation) of wastewater will need to comply with the Guidelines for Sewerage Systems – Use of Reclaimed Water (ANZECC/ARMCANZ 2000) and Site Specific Type Approval by the NT Department of Health and Community Services (DHCS). This will require the proponent to: • conduct a detailed assessment of areas proposed for treatment and disposal using the DHCS Site

Report template; • evaluate the site constraints in order to choose the most suitable system for treatment and disposal of

wastewater; and • submit the report to DHCS supporting an application for the Site Specific Type Approval. Treatment

and disposal systems must comply with the requirements of the DHCS Code of Practice for Small On-site Sewage and Sullage Treatment Systems and the Disposal and Reuse of Sewage Effluent.

7 [8] IV Pending Prior to commissioning of plant

NT DIPE DHCS

The proponent will liaise with DIPE, DHCS and other NT Government agencies to design the most environmentally-appropriate irrigation system for the site.

7 [8] IV Pending At detailed design phase NT DIPE, DHCS

The proponent shall consult with relevant Northern Territory Government agencies on treatment and disposal methods of wastewater, in particular, disposal by on-site irrigation, with a view to avoiding direct discharge to the waters of Darwin Harbour.

5 IV Pending At detailed design phase NT DIPE DHCS

EA

The proponent will evaluate (during the design phase) the feasibility and benefit of using local hardwoods for landscaping and soaking up wastewater used for irrigation.

IV Pending At detailed design phase NT DIPE

To avoid impacts on the ecological integrity of surrounding dry rainforest, treated effluent will not be used to irrigate this vegetation.


NT DIPE

DISCHARGE OF WASTEWATER & STORMWATER TO DARWIN HARBOUR The proponent has indicated that there will be no point-source discharge of wastewater to the Harbour from construction activities or temporary facilities during the construction phase.

II CEMP 12.2 During construction of plant site

NT DIPE

Uncontaminated stormwater will be segregated from potentially contaminated streams and disposed of by direct discharge to adjacent waters. Stormwater collected within the process area will be routed to a drain sump and oily derivatives removed prior to discharge.


Once the design of the wastewater treatment system is completed, the proponent will confirm with DIPE the conditions under which direct discharge to the Harbour may be done (in contingency situations). If such discharge is considered a risk to nearby aquaculturists, the proponent will model likely trajectories and liaise with these facilities to develop contingency plans to protect their operations. The proponent will need a Waste Discharge Licence to release treated effluent to the Harbour.


NT DIPE







EA Report

VOLUME OF EMP WHICH


(I – IV)

ACTION CODE



COMPLIANCE STATUS

If direct discharges of wastewater are required, modelling of the effluent mixing zone shall be undertaken to the satisfaction of NT Government agencies to ensure that sufficient dilution will occur at the proposed discharge point to minimise impacts on nearby habitats.

5 IV Pending Prior to commissioning of plant

NT DIPE EA

POTENTIAL FOR RADIOACTIVE WASTE STREAMS Although levels of naturally occurring radioactive materials (NORMs) in the feed gas will be low, the proponent will comply with all applicable NT regulations and guidelines should there be any radioactive wastes requiring disposal.

IV Pending Throughout life of project DBIRD NT DIPE

DISPOSAL OF SOLID & SEMI-LIQUID WASTES The proponent will actively pursue waste minimisation and recycling opportunities to reduce solid and semi-liquid waste streams where possible. An Operational Waste Management Plan, prepared as part of the EMP, will further detail the proponent’s approach to managing these wastes.

IV Pending During operation of plant (also applicable to minimisation of construction wastes)

NT DIPE

Non-hazardous wastes (e.g. ceramic balls, biological sludge and domestic garbage) will be disposed of by waste management contractors and will meet requirements of OEH.

IV Pending During operation of plant NT DIPE (OEH)

Wastes not suitable for disposal at the Shoal Bay Waste Disposal Site (e.g. waste oils, biological sludge and spent solvents) will be disposed of by commercial waste management contractors. The proponent will review waste-tracking documentation to ensure these wastes are disposed in a manner approved by OEH.


NT DIPE

CONSTRUCTION WASTES Where practical, the proponent will use cleared terrestrial vegetation and/or mangroves for rehabilitation. Cleared vegetation will not be stockpiled on-site (to avoid creating breeding habitat for biting insects).

II CEMP 2.3, CEMP 12.2

During construction of plant site

NT DIPE

Stockpiled vegetation, beyond that which can be chipped for re-use onsite, will be disposed of by burning in accordance with appropriate permits.


NT DIPE

To avoid land subsidence, geo-technical advice will be sought if vegetation will be left in place and covered with fill.


NT DIPE

Removal of domestic wastewater will be contracted to a local waste management company and the proponent will require waste tracking documentation to ensure disposal meets the requirements of OEH, DHCS and PAWA.


NT DIPE, DHCS, PAWA

Waste oils will be collected and disposed of properly through a commercial waste management contractor.


NT DIPE

A temporary area will be established for stockpiling scrap metal, which will be collected for off-site recycling and/or disposal. Construction wastes will not be disposed of on-site.


NT DIPE

A full description of the proponent’s plans for management of construction wastes will be included in the Construction Environmental Management Plan (as part of the EMP)

II CEMP 12 Prior to commencement of construction

NT DIPE

SPENT AMINE The plant design will facilitate collection and re-use of amine. If disposal is required, the proponent will include options for disposal in its Operational Waste Management Plan prepared as part of the EMP.

IV Pending At detailed design phase (prior to commissioning)

NT DIPE

CARBON BEDS (containing waste mercury) The proponent recognises that carbon beds containing mercury may not be suitable for disposal at any landfill site and will include options for treatment and disposal in its Operational Waste Management Plan.


NT DIPE

WASTE OIL (Operational Phase) The proponent will liaise with OEH to develop preferred and contingency plans for management of waste oil.

8 IV Pending Prior to commissioning of plant

NT DIPE

DREDGING & DISPOSAL OF SPOIL







EA Report

VOLUME OF EMP WHICH


(I – IV)

ACTION CODE



COMPLIANCE STATUS

The proponent will develop a Dredge and Spoil Management Plan as part of its EMP in consultation with the DPC, OEH and DBIRD (Fisheries). This Plan will include further characterisation of sea-bed sediments (to refine predictions about plumes) and a “Reactive Monitoring Program” (to detect and deal with unacceptably high turbidity from dredge-related activities). Monitoring will include ensuring the continued health of coral assemblages at Channel Island.

9 [6] III Pending Prior to commencement of dredging

DPC, DIPE (OEH),

DBIRD

The proponent will need to apply for a Waste Discharge Licence for either side-casting spoil directly into the Harbour (if this activity is permitted) or discharge of decant water from land-based settlement ponds.

III Pending Prior to commencement of dredging

DIPE (OEH)

To avoid unacceptable cumulative impacts from discharge from both Wickham Point and East Arm Port (if dredging for these coincide) and to facilitate use of suitable spoil from the LNG project for the Port project, the proponent will liase with the DPC and OEH to coordinate their dredging schedules and monitoring programs.

III Pending Prior to commencement of dredging

DIPE (OEH), DPC

The proponent will liaise with OEH to ensure that dredging works are done in an acceptable manner and that excess dredge material will be managed and disposed of to the satisfaction of OEH.

III Pending Prior to and during dredging activity

DIPE (OEH)

The proponent will liaise with nearby aquaculturalists to avoid unacceptable impacts on their operations from plumes generated from dredging activities.


DBIRD (Fisheries)

Appropriate construction methods and timing will be adopted to minimise the potential for dispersion of turbid water plumes towards the Channel Island coral community.


DBIRD (Fisheries)

The Construction Environmental Management Plan shall include a Dredge and Spoil Disposal Management Plan that evaluates options for dredging, excavation and spoil disposal and addresses potential environmental impacts. The Plan shall include proposed measures to ensure protection of the Channel Island coral assemblages which are listed in the Register of the National Estate, implementation of baseline studies, turbidity plume monitoring, a reactive monitoring program (if required), and contingency measures to be implemented if monitoring indicates adverse impacts. Any proposal for sidecasting of spoil shall be subject to additional sedimentation and turbidity modelling and may require implementation of a reactive monitoring program to ensure that the coral assemblages of Channel Island are adequately protected.

6 III Pending Prior to and during dredging activity

NT DIPE EA

SHIPPING An emergency management plan addressing LNG carrier operations at sea, in Darwin Harbour and at the loading jetty shall be developed in consultation with relevant authorities such as the Darwin Port Corporation and Australia Maritime Safety Authority. The plan shall include matters such as measures to ensure compliance with national and international safety regimes, reporting procedures and organisational responsibilities in the event of incidents, control of incident responses, contingency measures to minimise risks to human safety and the environment, minimum resources to be held on ship and at berth to deal with credible contingencies, and interactions with shore-based or other emergency response team.

8 IV Pending Prior to commencement of shipping activities (plant operation)

AMSA DPC EA

To minimise the risk of grounding or collision, shipping movements will be coordinated through the DPC, including escort by tugs to and from the loading jetty and with the RAN. A 500 m “moving exclusion zone” around each ship is proposed. The navigational risk associated with shoals of Charles Point Patches will be addressed by continued liaison between the proponent and the DPC.

IV Pending Prior to commencement of shipping activities (plant operation)

DPC RAN

To minimise the potential for direct or indirect disturbance to dugongs off Wickham Point, LNG tanker speeds will be kept at an appropriately low level within the Harbour, as agreed with NT Government authorities.

IV Pending During shipping activities (plant operation)

NT DIPE

To minimise risks to dugongs and sea turtles that forage around Channel Island, LNG shipping operations will remain away from the Channel Island area.

IV Pending During shipping activities (plant operation)

NT DIPE

To minimise potential damage from grounding, collision or other incident, the proponent will prepare, maintain, test and review Emergency Response Plans, LNG Accident Response Plans and Oil Spill Contingency Plans (prepared in consultation with the DPC, DIPE [Marine Branch] and other relevant NT Government agencies).

10 [18] & 11 [19] IV Pending Prior to commencement of shipping activities

DPC, NT DIPE AMSA







EA Report

VOLUME OF EMP WHICH


(I – IV)

ACTION CODE



COMPLIANCE STATUS

An oil spill contingency plan for the port facility shall be prepared by the proponent, within the overall context of the Darwin Port Corporation’s Oil Spill Contingency Plan. The site specific plan shall include an assessment of potential risks of spills and credible volumes, potential oil spill trajectories, maps of priority areas for protection including aquaculture facilities, deployment of equipment to protect priority areas, integration with the Darwin Port Corporation Plan, inventory of equipment to deal with control and clean-up (including with Northern Territory authorities).

12 Pending Prior to commencement of shipping activities

DPC NT DIPE

EA

LNG carriers will be designed, constructed, maintained and operated in compliance with international standards and subject to regular survey and inspection by vessel Classification Societies.

IV Pending Prior to commencement of shipping activities

DPC

Recognised international guidelines will be used in the design and construction of the LNG jetty and in the establishment of operating procedures for ship manoeuvres and cargo transfer.

III, IV Pending At detailed design phase DPC

RESTRICTED PUBLIC ACCESS Recreational fishing off the northern tip of Wickham Point will not be affected by the LNG plant: the only restrictions will be adjacent to the loading jetty and construction dock, both of which are well away from the area of greatest fishing interest. There will be no restriction of access to landing in the region of the old leprosarium.

IV Pending Throughout life of project NT DIPE

Any unusual, planned temporary interruptions to the activities of recreational fishermen, mariners and other users of the harbour as a result of barge movements will be notified to the Darwin Port Corporation and advertised in the local media.


DPC

HAZARD & RISK ANALYSIS During the detailed design phase, the proponent will complete the following: • a final HAZOP (Hazard & Operability) Study, to identify all potential scenarios involving failure of

valves/controls and other upset conditions; • a final QRA (Quantitative Risk Assessment), to identify, assess, evaluate and manage all potential

risks associated with the project; and • a detailed Safety Report for the LNG plant, in accordance with relevant Worksafe Australia Standards

and prepared on the basis of the HAZOP and QRA studies above.

IV Pending At detailed design phase DBIRD, Worksafe Australia

All practicable measures to prevent hazardous incidents and to mitigate their consequences will be adopted.

IV Pending At detailed design phase DBIRD, Worksafe Australia

TRANSPORT OF HAZARDOUS MATERIALS The proponent will do an assessment of hazardous wastes transported to and from the facility and prepare contingency plans to deal with any accidental spillage.


NT DIPE

INCREASED ROAD TRAFFIC (Construction Phase) Bechtel will liaise with the Department of Transport and Works to plan the routing and timing of truck movements during construction activities so as to minimise disturbance to commuter traffic.


DTW NT DIPE

Use of the road network for transport of materials and equipment will be in keeping with DIPE regulations and is not expected to have significant impact on commuter traffic.


DTW NT DIPE

Potential road damage from the transport of heavy equipment will be avoided or minimised through use of barges.


NT DIPE

SAFETY REPORT The proponent will consult with relevant NT Government agencies (during the detailed design phase) during development of a comprehensive Safety Report that meets the requirements of the National Code of Practice for Major Hazard Facilities.

IV Pending At detailed design phase DBIRD

CLEARING OF VEGETATION Clearing of vegetation will be staged to meet the minimal requirements of constructing and operating the plant.

II CEMP 2.1

During construction of plant site

NT DIPE

The proponent’s EMP will include measures aimed specifically at minimising loss and disturbance to remaining dry rainforest and mangrove habitat at Wickham Point, including measures to monitor and control weed and feral animal incursions, and measures to minimise fire risks.

12 [11] II, IV CEMP 1,6,10,11

Prior to commencement of construction, and regular monitoring thereafter

NT DIPE DPIF PWC







EA Report

VOLUME OF EMP WHICH


(I – IV)

ACTION CODE



COMPLIANCE STATUS

The proponent shall include, as part of the Construction and Operational Environmental Management Plans, specific measures to minimise loss and disturbance to remaining mangrove and dry rainforest habitat at Wickham Point as a result of the construction and operation of the proposed plant. This shall include measures to avoid unnecessary clearing and disturbance during construction, measures to monitor and control weed and feral animal incursions, and measures to minimise fire risks.

4 II, IV CEMP 1,6,10,11

Prior to commencement of construction, and regular monitoring thereafter

NT DIPE EA

DPIF PWAC

SELECTION OF DRY RAINFOREST OFFSET AREA(S) The proponent will continue to liaise with DIPE to identify an acceptable dry rainforest mitigation strategy, including identification of an appropriate area (size and location).


NT DIPE

MONITORING OF MANGROVES Monitoring of mangroves adjacent to the facility will be done by the proponent. The proponent will liaise with DIPE and NTU to ensure that current and appropriate methodology (for the measurement of productivity is used.

II CEMP 10 Prior to commencement of construction, and regular monitoring thereafter

NT DIPE

FAUNA HABITAT Fauna habitat surrounding the plant site will be protected by fencing, with access prohibited. II CEMP 11.5 After site clearing and

throughout life of project NT DIPE

If required by DIPE, the proponent will mitigate the potential obstacle the construction groyne might pose to faunal movements, by constructing earth ramps.

II CEMP 11.4 Prior to plant construction NT DIPE

MARINE BIOTA The proponent will mitigate risk to marine biota by minimising the discharge of potential contaminants into the Harbour and by enduring that discharges comply with relevant guidelines of the National Water Quality Management Strategy Guidelines and with all requirements of any Waste Discharge Licences for the project.


NT DIPE

FIRE, WEEDS & FERAL PESTS In consultation with DIPE, the proponent will produce and implement a comprehensive weed management plan prior to construction of the facility.

II CEMP 1 Prior to commencement of plant construction

NT DIPE DPIF

All activities will fully comply with requirements of the Weeds Management Act. II, IV CEMP 1

Throughout life of project NT DIPE DPIF

A Site Management Plan will include provisions for • cleaning and inspection of construction equipment prior to deployment on site; • monitoring for introductions (of weeds and feral pests) and their subsequent removal; and • fire prevention and control.

II CEMP 1 CEMP 6, CEMP 11

Prior to commencement of plant construction

NT DIPE DPIF PWC

Introduction of weeds and plant pathogens will be prevented through vehicle washdown and inspection procedures, to be developed in conjunction with the Department of Primary Industries and Fisheries.

II CEMP 1 During construction of plant site

DPIF

A feral animal control programme will be developed on the basis of advice from the Parks and Wildlife Commission.

II CEMP 11.1 Throughout life of project PWC

EXOTIC MARINE PESTS All shipping under control of the proponent will comply with the Australian regulations for the management of ballast water and general AQIS guidelines to ensure no ballast water exchange occurs within or near Darwin Harbour.

III, IV Pending Prior to and during shipping activities

DPC AQIS

The proponent will liaise with DBIRD regarding the exotic marine pests monitoring program and mitigation of potential impacts from vessels servicing the facility.

III, IV Pending Prior to and during shipping activities

DBIRD

NOISE In the event that pile-driving is considered necessary, the proponent will model potential noise impacts on the residents of Darwin and Palmerston. If findings indicate a significant potential for disturbance, a Noise Management Plan will be prepared, in consultation with OEH and implemented by the proponent.

II CEMP 5.4 Prior to commencement of plant construction

NT DIPE

In the event that explosives are required (e.g. to prepare site for construction), noise reduction measures, such as the use of weighted blankets, will be adopted and in accordance with appropriate permits.


NT DIPE







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A detailed modelling study will be done after completion of the design phase to refine preliminary predictions of noise generation.


To minimise risk of disturbance to the public, construction work, including blasting, will be done during daylight hours where practicable, when background levels of noise at the nearest populated areas will be greatest. Some activities, such as hydrotesting, may be required outside of daylight hours.


NT DIPE

The proponent will ensure that noise during construction and operation of the plant will be managed to the satisfaction of OEH and comply with the Waste Management and Pollution Control (Environmental Noise) Regulations (when these come into effect).

II, IV CEMP 5.2 Throughout life of project NT DIPE

Noise levels on site will be monitored and, in the event of complaints, actions to rectify will be undertaken if possible.


NT DIPE

The potential for dust generation will be minimised by shaping of stockpiles, spraying of cleared areas with water and control of vehicle speeds.


NT DIPE

BITING INSECTS To avoid creating mosquito breeding areas, the proponent will comply with the NT Government’s guidelines “Construction Practice near Tidal Areas in the Northern Territory – Guidelines to Prevent Mosquito Breeding” (Whelan 1988).


DHCS

The proponent will prepare a detailed Biting Insects Management Plan to comply with requirements of the DHCS and to include in the final EMP.

II, IV CEMP 3.2

Prior to commencement of plant construction

DHCS

Personal protection of employees from biting midges will be employed and induction training implemented to ensure that the problem is managed in accordance with recommendations by DHCS, and the proponent’s approach will be detailed in the EMP.

II, IV CEMP 3.8

During construction of plant site and throughout life of project

DLNG Project

RADIATION Although the occupational risk from radiation is considered to be low, the proponent will develop procedures for protecting personnel from naturally occurring radioactive materials (NORM) that may be associated with the LNG feed gas (e.g. during plant shutdown and maintenance).


DBIRD

When final equipment selection is done (during the design phase), any apparatus that is likely to contain radiation sources and/or irradiating equipment will be identified, and operation of this equipment will comply with provisions of the NT Radiation (Safety Control) Act.


DBIRD

VISUAL IMPACTS Design measures will be implemented where practical to minimise the potential visual impact of the development.

IV Pending At detailed design phase DLNG Project

LIGHT EMISSION (at night) To avoid unacceptable impacts, the proponent will investigate (during the design phase) opportunities to minimise light emission at night.

IV Pending At detailed design phase DLNG Project

CONSTRUCTION WORKFORCE An induction programme for the operational workforce will cover all aspects of health, safety and the environment. It will educate workers on the cultural and natural heritage values of the plant site and on the reasons for the application of environmental management practices.


NT DIPE

The proponent will commission a skills audit of the Darwin region to update their information on availability of skilled construction workers in the local labour market.


DLNG Project

DISCOVERY OF ARCHAEOLOGICAL/HERITAGE SITES & ARTEFACTS Five “highly significant” prehistoric middens (MA12, MA 13, MA 15, MA 18 AND MA 22) adjacent to the development footprint will be protected by erecting fencing around it and prohibiting entry and heavy machinery access to within 20 m.


DIPE (Heritage)

For Sites MA 14, MA 16, MA 19 and MA 21, the proponent will obtain a permit to remove the middens, under Section 29 of the Heritage Conservation Act.


DIPE (Heritage)

Newly discovered Site MH 4 is also likely to be subject to an application for disturbance and is currently the subject of further investigation in cooperation with the NT Heritage Conservation Branch (of OEH).


DIPE (Heritage)







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The proponent will continue to work with OEH to establish a comprehensive procedure for the discovery of archaeological/historic sites, which will be completed by the proponent during development of the Construction EMP and endorsed by OEH before construction begins.


DIPE (Heritage), AAPA,

Larrakia Nation

The proponent will continue to work with OEH to establish an Archaeological Sites Register for Wickham Point.


DIPE (Heritage)

The proponent supports a proposal by OEH to have an archaeologist on-site during initial land clearing, or alternatively be on alert to enable a rapid response and assessment should any additional sites or objects be discovered during clearing activities.


DIPE (Heritage)

To comply with the Heritage Conservation Act, the proponent will inform OEH of any new archaeological sites or features discovered prior to or during the construction and operational phases of the project.

II CEMP 8.1 During plant construction and operation

DIPE (Heritage)

On discovery of new archaeological sites or objects, vegetation clearing and other threatening activity will cease in the area of the site until OEH has a chance to inspect the site and advise on when/how the threatening activity can recommence.

II CEMP 8.3 During plant construction and operation

DIPE (Heritage)

ABORIGINAL SACRED SITES The proponent will consult with AAPA and confirm that no sacred sites or burial sites will be affected by the proposed expansion to a 10 MTPA facility and will continue to liaise with this agency on an ongoing basis prior to and during the construction phase.

II CEMP 8 Prior to and during plant construction

AAPA

A current Authority Certificate will be obtained from AAPA prior to commencement of any on-site works.


AAPA

The proponent will establish a “Heritage Issues Committee,” comprising representatives from OEH, AAPA and the Larrakia Association, to act as an advisory body for procedures regarding sacred sites and burial sites on Wickham Point.


DIPE (Heritage), AAPA,

Larrakia Nation

The proponent shall establish a liaison committee to provide for consultation on issues affecting Aboriginal interests throughout the detailed design, construction and operational phases of the proposal.

Prior to commencement of construction, and throughout project life

NT DIPE EA

EROSION & CONTROL OF SEDIMENTATION The proponent will submit, as part of their EMP, a draft Erosion and Sedimentation Control Plan to DIPE for approval prior to any construction works. This Plan will confirm key drainage flows across the site and specify a range of management measures to minimise erosion and siltation of the surrounding environment during plant construction and operation.


NT DIPE

ACID SULFATE SOILS The proponent will prepare an Acid Sulfate Soil Management Plan to cover areas within the footprint of the 10 MTPA plant. The Plan will include ground-truthing to confirm areas on-site that may be at risk from acid sulfate soil characteristics and procedures to be adhered to by the construction contractor.

13 [7] II CEMP 7 Prior to commencement of plant construction

NT DIPE

The Acid Sulfate Soil Management Plan will include monitoring of leachate from any soil or spoil retention areas and reclamation areas, and contingency measures in the event leachate is found to be unacceptably acidic. The Plan will be submitted to DIPE for review and endorsement prior to the commencement of construction.

13 [7] II CEMP 7 Prior to commencement of plant construction

NT DIPE

The proponent shall include, as part of the Construction and Operational Environmental Management Plans, an Acid Sulfate Soil Management Plan and Monitoring Program. This Plan shall include sampling and analysis of potential acid sulfate soils, monitoring of leachate from any soil or spoil retention areas and reclamation areas, and contingency measures in the event leachate is found to be excessively acidic.

7 II CEMP 7 Prior to commencement of plant construction

NT DIPE EA

FUEL STORAGE Fuel storage at the facility will fully comply with AS 1940 (1993) requirements for “The storage and handling of flammable and combustible liquids” on-site, including adequacy of bunds to fully contain the largest potential spill (and water from a 24-hr rainfall event), properly-sited and maintained sumps, synthetic liners under tanks and drums, and a comprehensive inspection and emergency response systems.

II, IV CEMP 12.13 During plant construction and operation

NT DIPE

SUSTAINABILITY







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The proponent’s EMP will address sustainability issues in a “triple bottom line” approach, integrating environmental, social/cultural and economic factors. These factors will become “Key Result Areas,” with “Key Performance Indicators” determined for each area.

IV Pending During plant operation phase NT DIPE

REVISED/ FINAL ENVIRONMENTAL MANAGEMENT PROGRAM The proponent will prepare an LNG Plant Environmental Management Plan that will include specific management and monitoring actions to be implemented by the proponent to achieve sound environmental management of the plant site and will build on prior commitments made for the 3 MTPA facility. Potential impacts and associated mitigation strategies will include all phases of the plant’s life.

I-IV Applicable to all EMP actions


NT DIPE, EA

The final EMP will be based on all matters involving regulatory compliance as well as corporate requirements to ensure the facility has an appropriate and effective Health, Safety and Environmental Management System.

14 [2] I-IV Applicable to all EMP actions


NT DIPE, EA

Final plans to be integrated into the EMP will incorporate consideration of the additional level of risk associated with the expanded project and advice from the NT Government and Environment Australia.

14[2] I-IV Applicable to all EMP actions


NT DIPE, EA

The EMP will be referred to relevant NT agencies and Environment Australia for review prior to finalisation, after which it will become a public document.

14[2] I-IV Applicable to all EMP actions


NT DIPE, EA

Phillips undertakes to manage the area within the boundaries of the LNG plant in an environmentally responsible manner and will cooperate with the NT Government in management programmes as agreed in the final EMP for the site.

I – IV Applicable to all EMP actions


NT DIPE EA

The proponent shall prepare Environmental Management Plans covering all aspects of environmental management and monitoring for the design, construction and operation of the proposed LNG plant at Wickham Point. The EMPs shall include any additional measures for environmental protection and monitoring contained in recommendations made by the Commonwealth and Northern Territory Governments in respect to the proposal.

11 I – IV Applicable to all EMP actions


NT DIPE EA

EMERGENCY RESPONSE PLANS Emergency Response Manuals The proponent will prepare emergency response manuals to cover the conceivable emergency situations at the plant and marine terminal, including situations off-site that could impact these facilities. The proponent will liaise with appropriate civil and port authorities to develop an emergency plan for the entire facility, to assist in continual review of the plan and procedures, to plan and run joint training and emergency exercises, and to develop effective and efficient communications during an emergency.

[15] IV Pending


DBIRD, NT Emergency

Services, DPC

Cyclone Response Procedures To ensure a well-defined procedure is in place for safety shutdown and to secure the facility, the proponent will develop a cyclone contingency plan in consultation with the Darwin Port Corporation, NT Emergency Services and other government agencies involved in emergency management for the Darwin, Palmerston and Litchfield region. This plan will mitigate risk to employees, the general public and the facility, and the infrastructure at the plant will be designed to minimise the risk of significant damage from cyclones.

IV Pending Prior to commencement of construction

DBIRD, NT Emergency

Services, DPC

When a cyclone is imminent, the plant will be shutdown and hydrocarbon inventory will be minimised. IV Pending During plant operation phase DBIRD, NT Emergency

Services

CORPORATE RELATIONS MANAGEMENT PLAN







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The proponent’s Corporate Relations Management Plan will establish the following: • a Corporate Relations Manager and Department; • a Public and Community Relations Program; • a Larrakia Liaison Committee; • a CASA/Air Service Australia Liaison Link; and • an internet web site.

I No action code identified


DLNG Project

COMPLIANCE AUDITING & REPORTING The proponent will be responsible for regular audits and reviews of the facility’s environmental and safety management, including both on-site auditing and review of performance reports.

I - IV Applicable to all EMP items


NT DIPE

Additional inspections will be done in the event of significant environmental incidents, in conjunction with relevant government authorities.



NT DIPE

The proponent will meet requirements for any additional monitoring and reporting under the Waste Management and Pollution Control Act.



NT DIPE

The proponent will produce an annual audit report to DBIRD, DIPE and Environment Australia (as required) and have a triennial review of the EMP.


During plant construction and operation

NT DIPE

The proponent will do regular audits of its Environmental Management System, including assessment of the objectives, organisational structure, responsibilities, procedures, processes and resources available at the site.


During plant construction and operation

DLNG Project

MONITORING COMMITMENTS For the 10 MTPA project, the proponent will build on the following monitoring commitments made for the 3 MTPA plant: • abundance of weeds and feral animals in undisturbed areas of Wickham Point; • abundance of biting insects within the plant site; • effects of dredging on the coral communities of Channel Island and northeast Wickham Point; • productivity of mangroves adjacent to the plant site; • quantity, quality and methods of disposal of construction and operational wastes; • confirmation of the quantity and quality of atmospheric emissions; • volumes and quality of wastewater discharges, including effluent dispersion studies; • concentrations of heavy metals, TBT and total petroleum hydrocarbons (TPH) in the marine sediments and

selected marine biota in the vicinity of the jetty and construction dock; and • contributing to monitoring programs for introduced noxious marine pests.

I - IV N/A Prior to commencement of construction, and throughout project life (timing dependent on specific environmental factor to be addressed)

NT DIPE

DECOMMISSIONING At the end of the project life (estimated at 20-25 years), the plant will be decommissioned in accordance with the best environmental standards applicable at the time.

15 IV Pending Prior to completion of gas reserves and project decommissioning

NT DIPE, DBIRD

Plant equipment and piping will be purged of hydrocarbons, and plant and office equipment will be sold or disassembled and sold as scrap, or disposed of in accordance with regulatory guidelines. Regulatory guidelines will also be followed for dismantling of the construction dock and product-loading jetty.

IV Pending Prior to completion of gas reserves and project decommissioning

NT DIPE, DBIRD

The proponent will rehabilitate the site in consultation with the NT Government, if the site is not sold and will not be used for other purposes.

IV Pending Prior to completion of gas reserves and project decommissioning

NT DIPE, DBIRD



5.2 ENVIRONMENTAL COMPLIANCE AND AUDITING PROCEDURES

(CONSTRUCTION PHASE) Compliance with applicable governmental laws, standards and regulations and with internal procedures (including those described in this EMP) begins with the primary contractor (Bechtel) and its site sub-contractors. DLNG Project will be responsible for assuring that its EMP commitments are being met by auditing contractors’ performance and requiring corrective actions to address areas of non-compliance with internal and external regulations and procedures. Bechtel will be responsible, at a minimum, for assuring compliance with EH&S procedures and protocols for the activities for which it responsible. These responsibilities are outlined in more detail in individual construction phase environmental management plans and procedures. 5.2.1 Environmental Responsibilities (Contractor and Sub-contractors) In general, Bechtel directly and through its sub-contractors will meet its responsibilities for the construction phase by:

1) developing robust procedures that will mitigate potential environmental effects,

2) providing training to its workers,

3) developing and implementing procedures to address incidents,

4) acquiring applicable permits or authorizations for specific construction-related activities,

5) submitting required notifications and/or reports to government agencies, and

6) auditing its compliance with regulatory requirements and its internal procedures. To accomplish these responsibilities the Bechtel project team will have a Project Environmental Lead (PEL) assigned to the project that will be responsible for identifying the engineering requirements necessary to meet applicable environmental regulations. Bechtel will assign a Site Environmental Coordinator (SEC) that will be initially located in Brisbane and then will be moved to the job site when the construction activities begin. A local environmental consulting firm(s) will aid this SEC as required. The SEC, who will report to the Bechtel Site ES&H Manager, will have primary responsibility for construction environmental compliance and reporting at the job site. Bechtel Corporate Policy 111, “Environmental Compliance, Safety and Health,” formally establishes Bechtel’s overall commitment to conduct activities at all sites in a manner that protects the health and safety of the public and the environment. For the Darwin LNG Project, Bechtel has adopted a comprehensive ES&H management system that will be used to guide and manage ES&H performance. The Bechtel ES&H management system has 10 elements as follows:

• leadership and commitment; • strategic objectives; • organisation, responsibilities, resources, standards and documentation; • hazards and effects management; • planning and procedures; • implementation; • monitoring; • corrective action; • audit; and • management review.



The Bechtel ES&H Management Framework is provided in Volume II. Bechtel’s protocols for its environmental inspections and audits are detailed in an accompanying EMP titled “Environmental Inspections and Audits Plan”, also included in Volume II. 5.2.2 Environmental Responsibilities (Owner) DLNG Project will have a Safety & Environmental Specialist (S&ES) assigned to the project that will be responsible for managing and coordinating commitments made in the construction EMP and for compliance with DLNG Project’s Corporate EH&S policies. The S&ES will monitor Bechtel’s performance in meeting its environmental responsibilities by conducting frequent independent audits to assure Bechtel’s compliance with regulations and its internal procedures. The S&ES along with the Darwin Area Manager will liaise with the NT government officials to maintain open lines of communication, improve procedures, address issues and/or government concerns, recommend modifications or enhancements to the EMP and insure that the goals of continuous improvement for environmental management at the site are realized. The S&ES will also be the primary contact and have primary responsibility for DLNG Project’s EMP commitments not directly related to construction at the site. The S&ES will be part of a team that includes the DLNG Project Plant and Project Management team, Phillips Petroleum Company Australia Pty Ltd’s HSE Manager located in Perth, Australia, DLNG Project HSE personnel located in Houston, TX (USA) and ConocoPhillips corporate HSE specialists. A local environmental consulting firm will aid the S&ES to implement the various parts of the EMP. In addition to regular audits of Bechtel’s performance by the S&ES, several higher level audits of the effectiveness of Phillips Petroleum Company Pty Ltd environmental management systems for the Darwin LNG Project (construction phase) will be conducted by the Australasia Division (Perth) and ConocoPhillips Corporate Reviews and Assessment Division. 5.3 SUSTAINABILITY DLNG Project has undertaken to develop a reporting framework for assessing the design, construction and operation of the project consistent with the principles of Ecological Sustainable Development (ESD). Integration of the environmental, social and economic aspects of the project into a logic framework will enable DLNG Project to track its performance towards sustainable development of the LNG project. This will ultimately establish a tangible means to openly communicate the company’s goals, objectives and performance measures through a public Sustainability Reporting process. In its operations worldwide, Phillips Petroleum Company (now ConocoPhillips) strives to achieve the goal of being a responsible and conscientious corporate citizen, which is demonstrated in its 2000-2001 Social Investment Report (Phillips, 2001). Through this vision, four primary goals are identified in support for Education and Youth, Civic and the Arts, Health and Safety, and the Environment.



During the operations phase, DLNG Project will undertake the key stages outlined below in order to develop a sustainability framework for the LNG Project.

1. Define what ‘sustainability’ means at the corporate level (or, alternatively, specific to the DLNG project);

2. Definition of key principles that will be applied to the DLNG project (eg. waste minimisation, energy use and efficiency, resource use, etc);

3. Establishment of a set of objectives and targets (ie. key result areas, or KRA’s) for each environmental, social and economic factor;

4. A risk assessment of each of the potential KRA’s to determine their suitability to achieve the sustainability objectives selected for the DLNG project.

The establishment of the above framework will involve a process of stakeholder engagement at a number of progressive stages to ensure community input into the sustainable management of the DLNG Project once commissioned.


6. GLOSSARY °C Degrees Celsius µg/L Microgram per litre (essentially one part per billion) µm Micrometre (one thousandth of a millimetre) AAPA Aboriginal Areas Protection Authority AFMA Australian Fisheries Management Authority AFZ Australian Fishing Zone AGO Australian Greenhouse Office AHD Australian High Datum (a tidal measurement) ANZECC Australia and New Zealand Environment and Conservation Council AQIS Australian Quarantine Inspection Service Bcm Billion cubic metres CCNT Conservation Commission of the Northern Territory CO2 Carbon dioxide dB(A) Decibels (a measuring unit for noise) DBIRD Northern Territory Department of Business, Industry and Resource

Development DHCS Northern Territory Department of Health and Community Services DIPE Northern Territory Department of Infrastructure, Planning & Environment

(formerly DLPE, DTW & PWS) DLNG Darwin LNG DPC Darwin Port Corporation dwt Dead weight tonnes EA Environment Australia ES&H Environment, Safety & Health EIS Environmental Impact Statement EMP Environmental Management Plan EMT Emergency Management Team ERG Emergency Response Group ERM Emergency Response Manual ERP Emergency Response Plan ESD Ecologically Sustainable Development HCS Heritage Conservation Services, Branch of DIPE HES Health, Environment & Safety HSE ConocoPhillips Health, Safety and Environment Organisation JPDA Joint Petroleum Development Area (formerly known as the Zone of

Cooperation) km Kilometre/s KRA Key Result Areas LNG Liquefied Natural Gas LPG Liquefied Petroleum Gas m Metre/s MAGNT Museums and Art Galleries of the Northern Territory MHL Manly Hydrographic Laboratories Mkg Million kilograms (tonne) mm Millimetre/s MMBBL Million barrels MMCFD Million cubic feet per day mmscfd Million standard cubic feet per day MTPA Million tonnes per annum NGL Natural gas liquid NHMRC National Health and Medical Research Council NHT Natural Heritage Trust

6. GLOSSARY


nm Nautical mile NOI Notice of intent NOX Nitrogen oxides NTG Northern Territory Government OEH Office of Environment & Heritage OH&S Occupational Health & Safety OSCP Oil Spill Contingency Plan OSRG Oil Spill Response Group PAWA Northern Territory Power and Water Authority PEL Project Environmental Lead PER Public Environmental Report pers comm./s Personal communication/s ppm Parts per million ppt Parts per thousand ria Drowned river system S&ES Safety and Environmental Specialist (DLNG Project) SEC Site Environmental Coordinator SO2 Sulphur dioxide train LNG processing section of the plant VOC Volatile organic compound v/v air Volume per volume of air


7. REFERENCES Dames & Moore 1998. Darwin LNG Plant. Preliminary Environmental Management Programme. Report prepared for Phillips Oil Company Australia by Dames & Moore, Report No. R683. Phillips Petroleum Company 2001. 2000-2001 Social Investment Report. Bartlesville, Oklahoma. URS 2002. Darwin 10 MTPA LNG Facility. Public Environmental Report. Report prepared for Phillips Petroleum Company Australia Pty Ltd by URS Australia Pty Ltd, Report No. R841, March 2002.

Appendix A

ASSESSMENT REPORT 39

DARWIN 10 MTPA LNG FACILITY

(WICKHAM POINT)

ENVIRONMENTAL ASSESSMENT REPORTAND

RECOMMENDATIONS

by the

OFFICE OF ENVIRONMENT AND HERITAGE

DEPARTMENT OF INFRASTRUCTURE, PLANNING ANDENVIRONMENT

May 2002

Darwin 10 MTPA LNG FacilityAssessment Report 39

May 2002ii

TABLE OF CONTENTS

ABBREVIATIONS ……………………………………………………………………..….. v

EXECUTIVE SUMMARY…………………………………………………………….……. vii

LIST OF RECOMMENDATIONS FOR CURRENT PROPOSAL……….…..………..…. xi

LIST OF RECOMMENDATIONS FROM PREVIOUS PROPOSAL…………………… xvi

FIGURES (from PER prepared by URS Australia P/L, March 2002)

1.1 Location Plan: Timor Sea (Bayu-Undan field) and Darwin Harbour…………. xxi

1.2 Major Components of Plant on Wickham Point………………………………... xxii

1.3 Layout of Facility ………………………………………….…..…………...……. xxiii

1.4 Phillips’ Optimised Cascade LNG Process …………………………...……….. xxiv

1 INTRODUCTION AND BACKGROUND........................................................................ 11.1 Environmental Impact Assessment Process............................................................................ 1

1.2 Environmental Impact Assessment History............................................................................ 1

2 THE PROPOSAL............................................................................................................... 32.1 Objectives of the Expanded Proposal ...................................................................................... 3

2.2 Alternatives to the Proposal ..................................................................................................... 3

2.3 Major Components of the Proposal ......................................................................................... 42.3.1 Metering Station .................................................................................................................................42.3.2 LNG Plant...........................................................................................................................................42.3.3 LNG Ship-loading Facilities ...............................................................................................................42.3.4 Construction Dock ..............................................................................................................................42.3.5 LNG Tankers ......................................................................................................................................5

2.4 Key Differences between the 3 MTPA and 10 MTPA Proposals .......................................... 5

3 REGIONAL SETTING: DARWIN AND DARWIN HARBOUR………………………63.1 Physical....................................................................................................................................... 6

3.2 Areas with Significant Conservation Values and/or Management Issues ............................ 73.2.1 Biological............................................................................................................................................73.2.2 Cultural ...............................................................................................................................................73.2.3 Socio-economic ..................................................................................................................................8

4 ENVIRONMENTAL IMPACT ASSESSMENT…………………………………………94.1 Introduction ............................................................................................................................... 9

4.2 Integration of recommendations from assessments for the EIS and PER ........................... 9

4.3 Issues Raised in Submissions.................................................................................................. 104.3.1 Issues Outside the Scope of this Environmental Impact Assessment ...............................................11


May 2002iii

4.4 Further Impact Assessment Studies Relating to Proposed Expansion............................... 12

4.5 Atmospheric Emissions ........................................................................................................... 134.5.1 Existing Environment and Potential Impact on Air Quality .............................................................134.5.2 Adequacy of Modelling ....................................................................................................................134.5.3 Sulphur Dioxide (SO2)......................................................................................................................134.5.4 Nitrogen Oxides (NOx) .....................................................................................................................144.5.5 Potential Generation of “Acid Rain” (from sulphur dioxide or nitrogen oxides) .............................144.5.6 Potential Impacts on Public Health...................................................................................................154.5.7 Particulates........................................................................................................................................154.5.8 Odours ..............................................................................................................................................16

4.6 Greenhouse Gas Emissions..................................................................................................... 164.6.1 Greenhouse Gas Offsets....................................................................................................................16

4.7 Flaring (Heat Emissions) ........................................................................................................ 17

4.8 Wastewater and Stormwater Management .......................................................................... 184.8.1 Temporary Sanitation Facilities........................................................................................................184.8.2 Hydrotest Water................................................................................................................................184.8.3 Irrigation with Treated Wastewater and Stormwater ........................................................................194.8.4 Discharge (to Darwin Harbour) of Treated Wastewater and Stormwater.........................................204.8.5 Radioactive Waste ............................................................................................................................21

4.9 Solid and Semi-liquid Waste Disposal ................................................................................... 224.9.1 Adequacy of Shoal Bay Waste Disposal Site (SBWDS) ..................................................................224.9.2 Construction Wastes .........................................................................................................................224.9.3 Biological Sludge..............................................................................................................................234.9.4 Disposal of Cellulose/Molecular Sieves and Ceramic Balls .............................................................234.9.5 Spent Amine .....................................................................................................................................234.9.6 Carbon Beds (containing waste mercury) .........................................................................................234.9.7 Waste Oil ..........................................................................................................................................23

4.10 Impact of Rock Groynes ..................................................................................................... 24

4.11 Dredging and Disposal of Spoil .......................................................................................... 24

4.12 Risks from Shipping............................................................................................................ 254.12.1 Navigational Hazard from Charles Point Patches.............................................................................274.12.2 Berthing and Departure Procedures ..................................................................................................27

4.13 Hazards and Risks (public and environmental) ............................................................... 274.13.1 Hazard and Risk Analysis.................................................................................................................274.13.2 Cyclones ...........................................................................................................................................294.13.3 Lightning Strikes and Power Failures...............................................................................................294.13.4 Transport of Hazardous Materials ....................................................................................................294.13.5 Safety Report ....................................................................................................................................294.13.6 Environmental Performance of Kenai LNG Plant (Alaska)..............................................................30

4.14 Ecological Impacts............................................................................................................... 304.14.1 Dry Rainforest ( = monsoon vine thicket) ........................................................................................304.14.2 Mangroves and Salt-flat Habitat .......................................................................................................314.14.3 Impacts on Terrestrial Fauna ............................................................................................................314.14.4 Impacts on Marine Biota...................................................................................................................324.14.5 Fire, Weeds and Feral Pests ..............................................................................................................324.14.6 Exotic Marine Pests (from discharge of ballast from ships) .............................................................32

4.15 Noise...................................................................................................................................... 334.15.1 Construction Phase ...........................................................................................................................334.15.2 Noise during Upset/Emergency Operating Conditions.....................................................................334.15.3 Requirements under the NT draft Waste Management and Pollution Control (Environmental Noise)Regulations....................................................................................................................................................33


May 2002iv

4.16 Work Health Issues ............................................................................................................. 344.16.1 Biting Insects ....................................................................................................................................344.16.2 Radiation...........................................................................................................................................34

4.17 Impacts on Visual Amenity................................................................................................. 35

4.18 Socio-Economic Impacts ..................................................................................................... 354.18.1 Construction Work-force ..................................................................................................................354.18.2 Impacts on Commercial and Recreational Fishing in Darwin Harbour ............................................36

4.19 Cultural Impacts.................................................................................................................. 364.19.1 Discovery of Archaeological/Heritage Places and Objects...............................................................364.19.2 Aboriginal Sacred Sites ....................................................................................................................37

4.20 Other Issues.......................................................................................................................... 374.20.1 Mercury in Domestic (Industrial) Gas ..............................................................................................374.20.2 Requirements for Fill (during construction phase) ...........................................................................384.20.3 Erosion and Sedimentation ...............................................................................................................384.20.4 Acid sulfate soils...............................................................................................................................384.20.5 Anticipated Freshwater Usage (during construction phase) .............................................................384.20.6 Fuel Storage ......................................................................................................................................39

4.21 Sustainability ....................................................................................................................... 39

5 ENVIRONMENTAL MANAGEMENT PROGRAM ..................................................... 415.1 Introduction ............................................................................................................................. 41

5.2 Preliminary EMP (Dames and Moore, 1998b) ..................................................................... 41

5.3 Revised Environmental Management Program...................................................................... 415.3.1 Additions to Commitments in the 3 MTPA EMP.............................................................................425.3.2 Summary of Updated Environmental Management Commitments ..................................................435.3.3 Revised Environmental Management Plans (to be included in the proponent’s EMP) ....................43

6 CONCLUSIONS………………………………………….……………………………. 47

REFERENCES…………………………………………………………………………….. 50

APPENDICES

1. LIST OF RESPONDENTS TO THE PER ………………………………………………….. 52

2. ISSUES RAISED IN SUBMISSIONS …………………………….…………………………. 53

3. SUMMARY OF GOVERNMENT AND PUBLIC COMMENTS ON THE PER………… 55

4. ENVIRONMENTAL COMMITMENTS AND SAFEGUARDS ………………………….. 70


May 2002v

ABBREVIATIONS�g/m3 microgram (one millionth of a gram)/cubic metreAAPA Aboriginal Areas Protection AuthorityAHD Australian Height Datum (a measurement of height relative to mean sea level)AQIS Australian Quarantine and Inspection ServiceAMSA Australian Maritime Safety AuthorityBq/m3 Becquerel per cubic metre (a unit of radioactivity; = one disintegration or nuclear

transformation per second, per cubic metre)CASA Civil Aviation Safety AuthorityCBD Central Business District (of Darwin)CO2 carbon dioxideCPI corrugated plate interceptorDAC Darwin Aquaculture Centre (Channel Island)dB(A) decibels (a measuring unit for noise)DBIRD Northern Territory Department of Business, Industry and Resource

Development (formerly DPIF, DME)DHCS Northern Territory Department of Health and Community Services

(formerly THS)DIPE Northern Territory Department of Infrastructure, Planning & Environment (formerly

Department of Lands, Planning and Environment; Department of Transport andWorks; and Parks and Wildlife Commission)

DLPE Department of Lands, Planning and Environment (now part of DIPE)DPC Darwin Port CorporationDPIF Department of Primary Industry and Fisheries (now part of DBIRD)EIS Environmental Impact StatementEMP Environmental Management Program (or Plan)EPBC Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth

Act)ERM Emergency Response ManualERP Emergency Response PlanGHG greenhouse gasIMO International Maritime OrganisationLNG liquefied natural gasLPG liquefied petroleum gasm3 cubic metre (a volume 1 m x 1 m x 1 m)micron one millionth of a metreMAGNT Museums and Art Galleries of the Northern TerritoryMTPA million tonnes per annumMW megawatt (unit of power)NEPC National Environment Protection CouncilNEPM National Environment Protection MeasureNHMRC National Health and Medical Research CouncilNHT Natural Heritage Trustnm nautical mileNOI Notice of IntentNORM naturally occurring radioactive materialNOX nitrogen oxidesOEH Office of Environment and Heritage (in DIPE)OSCP Oil Spill Contingency PlanPAWA Northern Territory Power and Water AuthorityPER Public Environmental Reportpers comm. personal communication/s


May 2002vi

PM10 particulate matter (in air emissions) < 10 microns in sizeppb parts per billionppm parts per millionppt parts per thousandRAAF Royal Australian Air ForceSBWDS Shoal Bay Waste Disposal SiteTPA tonnes per annumSO2 sulphur dioxideTBT tributyltin (toxic anti-foulant added to boat paints)ZOC Timor Gap Zone of Co-operation between Australia and Indonesia (to be known in

future as the Joint Petroleum Development Area between Australia and East Timor)ZOCA Section A of the ZOC


May 2002vii

EXECUTIVE SUMMARY

In 1997, Phillips Oil Company Australia submitted to the NT Government a proposal to construct aLiquefied Natural Gas (LNG) facility at Wickham Point (on the Wickham Point Peninsula, betweenEast Arm and Middle Arm) in Darwin Harbour. The proposed facility comprised a single train plant toproduce LNG at a maximal rate of 3 million tonnes per annum (MTPA) from gas transported from theBayu-Undan field (in the Timor Sea) to Wickham Point via a sub-sea pipeline. (A “train” is aproduction pathway and related infrastructure, having its own process area at the facility.)

The proposed project included

� a sub-sea pipeline;

� a land-based facility for liquefaction of natural gas and storage of LNG;

� marine loading facilities; and

� a dedicated fleet of ships to transport LNG product.

The proposal went through a detailed Environmental Impact Assessment process, at the level of anEnvironmental Impact Statement (EIS) and received approval from Commonwealth and NorthernTerritory Environment Ministers in early 1998. The NT Government analysis of the project,comments and Supplement formed the basis of the Territory’s Environmental Assessment Report 24.

In March 2002, Phillips submitted a revised proposal for a 10 MTPA plant (comprising two trains,each with a maximal output of 5 MTPA) that could capture and process natural gas from additionaloffshore fields, e.g. the Greater Sunrise field in the Timor Sea.

The environmental assessment of the proposed 10 MTPA facility is being conducted at the level of aPublic Environmental Report (PER) primarily under the Northern Territory Environmental AssessmentAct 1982 and concurrently reviewed under the Administrative Procedures approved under theCommonwealth Environment Protection (Impact of Proposals) Act 1974.

Environmental impact assessment is the process of defining those elements of the environment thatmay be affected by a development proposal and of determining the significance, risks andconsequences of the potential impacts of the proposal. Recommendations arising from the assessmentaddress methods to mitigate these impacts.

The PER describes the predicted and potential environmental impacts of the expanded LNG facility,with particular emphasis on differences between the previously approved 3 MTPA LNG facility andthe proposed 10 MTPA plant. The PER also describes measures to avoid or mitigate these impacts.

This Environmental Assessment Report identifies the key environmental issues relating to the project(as described in the PER) and evaluates the adequacy and appropriateness of the proposed measures tomitigate the potential and anticipated impacts. Where the proponent’s commitments are consideredadequate and appropriate, they have been included, as proposed, in this Report. Where commitmentsor safeguards are considered incomplete or not specific enough, or particular impacts have not beenaddressed adequately in the PER, recommendations have been put forward to redress these issues.

Comments from the public and Northern Territory Government agencies on the PER, and theproponent’s responses to these comments, have been used to develop the recommendations made inthis Assessment Report.


May 2002viii

Major Issues

The major impacts of the proposed 10 MTPA facility compared to the approved 3 MTPA facility willresult from the increased capacity of the plant and will be as follows:

1. Increased area of ground disturbance, from 66.8 ha to 88.3 ha;

2. Increased demand for power generation, from 18.2 MW to 48.4 MW;

3. Increased operating work-force, from 75 to 120 personnel;

4. Increased demand for process water, from 6 to 12 m3/hr;

5. Increased volumes of waste-water requiring treatment/disposal, from 4.5 to 11 m3/hr;

6. Increased volume of storage tank hydro-test water discharge prior to plant start-up;

7. Increased volume of solid and semi-liquid waste generated and requiring disposal (from 143,050to 242,600 kg/yr);

8. Increased risk to the public and the environment from greater volumes of LNG storage tanks (from190,000 m3 to 360,000 m3);

9. Increased risk to the public and the environment from increased shipping movements, from 78visits to approximately 160 visits per year, and the navigation risk associated with using largervessels; and

10. Increased atmospheric and greenhouse gas emissions (especially CO2, which, at full plantcapacity, will be generated at a rate of 4.5 MTPA compared to 1.7 MTPA).

Conclusions

The Office of Environment and Heritage considers that the environmental issues associated with theproposed project have been adequately identified. Appropriate environmental management of some ofthese issues has been identified through the assessment process, whereas resolution of other matterswill be achieved through monitoring and management actions detailed in a comprehensiveEnvironmental Management Program (EMP).

In November 1998, a Preliminary EMP was produced (for the 3 MTPA proposal; Dames and Moore1998b) which incorporated comments by and approval conditions set by the Commonwealth and NTGovernments, based on their review of the Draft EIS (Dames and Moore 1998a). Phillips proposes tocomplete the EMP for the 10 MTPA facility in stages, before the start of construction, by building onthe commitments in the Preliminary EMP and focusing on the additional level of potentialenvironmental impacts associated with the expanded project. Comments submitted by the public andNorthern Territory Government during the review of the PER will also be used to develop newmitigation measures for impacts associated with the proposed expansion or to revise, whereappropriate, those developed for the 3 MTPA plant.

This final EMP will be subject to review and approval by relevant Northern Territory andCommonwealth Government agencies.

The EMP will be the major vehicle for implementing management and monitoring commitments madeby the proponent in the PER and the recommendations detailed in this Assessment Report. As such, itwill be a working document for the life of the plant and it will require continual review in the light ofoperational experience and changed circumstances.

The proposed expansion will have two main environmental impacts during the construction andcommissioning stages of development:


May 2002ix

� the clearing of an additional 21.5 ha of regionally-significant dry rainforest (monsoon vinethicket) which comprises a 32% increase over clearing for the 3 MTPA plant; and

� the discharge of an increased volume (not specified in the PER) of hydrotest water (possibly withchemical additives) from three LNG storage tanks instead of two and from a smaller tank forcondensate.

To offset the loss of dry rainforest, the proponent is working with the Department of Infrastructure,Planning and Environment (DIPE) to identify and acquire another area of equivalent or better qualityrainforest for conservation.

To mitigate potential impacts on marine biota from discharge of hydrotest water, the proponent hasundertaken to work with DIPE to identify appropriate treatment and release options (e.g. dilutionbefore release, release during tidal phases that will promote further dilution and transport out of theHarbour, release at a slow rate, etc.). If analysis of the proposed formulation of hydrotest waterindicates a potential for toxic impacts on marine life, the proponent will need to obtain a WasteDischarge Licence from the Office of Environment and Heritage to release this water into DarwinHarbour and must comply with all conditions attached to that Licence.

During the operational life of the facility, the expanded development will also have several significanton-going environmental impacts:

� Perhaps the most significant of these will be a 2.5x increase in greenhouse gas emissions,particularly CO2.

Section 4.5 of this Assessment Report discusses the implications of the increased production ofCO2, and a number of mitigating actions will be undertaken by the proponent in order to reduce oroffset the production of this greenhouse gas as the operation proceeds. (The plant will alsoproduce a number of other atmospheric pollutants; however, the proponent’s modelling of “worst-case” scenarios indicates that these will be kept within national and international guideline levels.)

� Another significant potential impact associated with the proposed expansion is an increased riskfor groundings, collisions or other incidents from the near doubling of visits by LNG vessels(especially the risk of oil spills).

At peak production, vessels will berth and load LNG every two to three days (instead of once perweek, for the 3 MTPA facility). The Hazard and Risk Assessment for shipping concluded that theestablished design, construction and operating practices of LNG vessels, combined with theDarwin Port Corporation controls and safety measures, will ensure that the risk of a major incidentresulting in spills from an LNG vessel will be very small. The increased shipping is thereforeconsidered to pose minimal additional risk compared to that for the 3 MTPA facility.

Despite the low risk, the proponent will develop site-specific oil spill contingency plans (OSCPs)for the construction and operation phases of the project. These OSCPs will integrate effectivelywith the Darwin Harbour OSCP and the Commonwealth’s National Plan to Combat Pollution ofthe Sea by Oil and other Noxious and Hazardous Substances. It will also identify options forutilising expertise and equipment from the industry-based Australian Marine Oil Spill Centre(Geelong).

� A third source of increased public and environmental risk will be from increased production (10instead of 3 MTPA) and a near doubling of volumes of LNG in storage tanks at Wickham Point.

The increased risk to people, the environment and adjacent facilities from potential incidentsrelating to increased production and storage of LNG was addressed in a Hazard and RiskAssessment study and report (Bechtel 2002, Appendix G of the PER). This report focuses on themain changes in risk profile between the 3 MTPA and 10 MTPA facilities: two LNG “trains” (i.e.


May 2002x

production pathways and related infrastructure) instead of one; greater LNG storage capacity; andmore frequent shipping.

The Hazard and Risk Assessment concluded that the codes and standards governing the design andoperations at the LNG plant will maintain, at an acceptably low level, potential hazards to sitepersonnel, the public and the environment. The remote location of the plant in relation toresidential areas provides a further safeguard to the public.

� Volumes of waste-water will increase nearly 2.5x, and solid and semi-liquid waste (e.g. domesticwaste, oils, sludge) will increase approximately 1.7x.

Phillips has undertaken to use all treated wastewater for on-site irrigation. Discharge to theHarbour will be considered only as a contingency option (e.g. during the wet season, if soils arealready saturated), and a Waste Discharge Licence will have to be obtained in advance from theOffice of Environment and Heritage.

The increased levels of solid and semi-liquid wastes were re-assessed, and the proponent hasdemonstrated that the volumes and range of non-hazardous and hazardous wastes can beappropriately managed and disposed of safely in accordance with the provisions of the WasteManagement and Pollution Control Act. The LNG plant will require one or more licences underthis Act and the Water Act to regulate emissions to air, management of wastes and any dischargesto Darwin Harbour. The proponent will be required to comply with all licence conditions andregulations under these acts, including regular compliance audits and reports.

Based on its review of the PER and the proponent’s Response to Submissions from relevant NTGovernment agencies and the public, the Office of Environment and Heritage considers that theproject can be developed and managed in a manner that avoids unacceptable environmental impacts,provided that the environmental commitments, safeguards and recommendations detailed in thisAssessment Report and in the final EMP are implemented, and regular compliance auditing andreporting are undertaken.


May 2002xi

LIST OF RECOMMENDATIONS FROM ASSESSMENT OF 10 MTPA PROPOSALDuring the implementation of proposals outlined in the PER, flexibility is necessary and desirable toallow for minor changes to the design and specifications that have been examined as part of thisassessment. Where it can be shown that such changes are not likely to have a significant impact on theenvironment, an adequate level of environmental protection may still be achieved by the followingrecommendations, modifications to these recommendations or by conditions attached to relevantstatutory approvals for these modifications.

These Recommendations have been cross-referenced to ones included in the previous assessment forthe 3 MTPA LNG plant and pipeline. The “ = “ symbol indicates that the new Recommendation isvirtually unchanged from the previous one; the “ ~ “ symbol indicates that the new Recommendationis similar to the previous one but has been substantially modified.

Subject to decisions that permit the Darwin 10 MTPA project to proceed (e.g granting of developmentpermits and issuance of both freehold and long-term leasehold titles), the recommendations resultingfrom the assessment are set out below.

Note: unless superseded by recommendations in the current Assessment Report, recommendations inthe previous Assessment Report (No. 24) should be considered current.

Recommendation 1

The proponent shall ensure that the proposal is implemented in accordance with theenvironmental commitments and safeguards

� identified in the Darwin 10 MTPA Facility Public Environmental Report and as modified inthe proponent’s response to issues raised by the public and NT Government agencies thatreviewed the PER; and

� as recommended in this Assessment Report (No. 39) which includes relevantrecommendations from the previous Assessment Report (No. 24).

[= Recommendation 1 in Assessment Report 24]

Recommendation 2

If expansion of the 10 MTPA plant is proposed, the revised project design shall be submitted tothe NT Government for further assessment under the NT Environmental Assessment Act 1982.

[ ~ Recommendation 3 in Assessment Report 24]

Recommendation 3

The proponent shall quantify the major emission sources during commissioning of the project,by periodic emission testing programs. Dependent on the results of this verification process, theproponent will establish a monitoring system for oxides of nitrogen (NOx) from key emissionsources at the facility and shall verify that standards contained in the Ambient Air QualityNational Environment Protection Measure (NEPM) are not exceeded.

Procedures for monitoring and reporting shall be developed in consultation with the Office ofEnvironment and Heritage and shall meet relevant NEPM requirements and AustralianStandards.

[~ Recommendation 13 in Assessment Report 24]Recommendation 4


May 2002xii

The proponent’s Environmental Management Program shall include a section specificallyaddressing commitments and strategies aimed at reducing greenhouse gas emissions. This shallinclude (for example) provisions for regular greenhouse gas audits, a process for continuousreview of new technologies to identify opportunities to reduce emissions, and benchmarkingagainst other LNG facilities with a view to achieving international best practice in terms ofcarbon dioxide emissions per unit of production. Opportunities for offsetting greenhouse gasemissions, including support for relevant research, shall also be addressed.

In developing its greenhouse gas strategy, the proponent shall consult with the Greenhouse Unitof the NT Office of Environment and Heritage, and the strategy shall be provided toEnvironment Australia.


Recommendation 5

This Assessment Report acknowledges the negotiations between the proponent, the CivilAviation Safety Authority (CASA), Darwin Airport authorities and other relevant agencies toresolve outstanding concerns regarding potential impacts from flaring on aviation. If continuingstudies indicate a potential significant risk to aviation, further analysis of hazards and risks toaircraft from flaring shall be required prior to the proponent’s final decisions on the design andoperation of flares.

[~ Recommendation 16 of Assessment Report 24]

Recommendation 6

If chemical additives used in hydrotest water pose a risk of toxicity to marine life in theHarbour, the proponent will require a Waste Discharge Licence. The Licence will require theproponent to analyse the hydrotest formulation to be used (to assess the potential toxicity tomarine biota) and to monitor the receiving water to ensure adequate dilution and dispersion toreduce toxicity to an acceptable level. Further, if there is a credible risk of toxicity in thedischarge, the proponent will provide adequate notice to nearby aquaculturists to allow themtime to implement desired precautionary measures. (This will comprise an additional safeguardto protect stock at these facilities.)

[New Recommendation]

Recommendation 7

Treatment and disposal (by irrigation) of wastewater will need to comply with the Guidelines forSewerage Systems – Use of Reclaimed Water (ANZECC/ARMCANZ 2000) and Site Specific TypeApproval by the NT Department of Health and Community Services (DHCS). This will requirethe proponent to

� Conduct a detailed assessment of areas proposed for treatment and disposal using the DHCSSite Report template;

� Evaluate the site constraints in order to choose the most suitable system for treatment anddisposal of wastewater; and


May 2002xiii

� Submit the report to DHCS supporting an application for the Site Specific Type Approval.Treatment and disposal systems must comply with the requirements of the DHCS Code ofPractice for Small On-site Sewage and Sullage Treatment Systems and the Disposal and Reuseof Sewage Effluent.


Recommendation 8

The proponent will consult with Office of Environment and Heritage to develop preferred andcontingency options for management and disposal of waste oil and will include these in itsEnvironmental Management Program.


Recommendation 9

The proponent’s Environmental Management Program shall contain a Dredge and SpoilDisposal Management Plan that evaluates options for dredging, excavation and spoil disposaland addresses potential environmental impacts. This Plan shall include proposed measures toensure protection of the Channel Island coral assemblages. The Plan shall also include a“Reactive Monitoring Program” that implements baseline studies (to set environmental triggersfor concern), turbidity plume monitoring, a reactive coral monitoring program (if required), andcontingency measures to be implemented if environmental triggers are exceeded or if monitoringdetects potentially unacceptable environmental impacts.

Development of the Dredge and Spoil Disposal Management Plan shall be done in consultationwith relevant NT Government agencies and shall be submitted to the NT Government forapproval prior to commencement of dredging.


Recommendation 10

An emergency management plan addressing LNG carrier operations at sea, in Darwin Harbourand at the loading jetty shall be developed in consultation with relevant authorities such as theDarwin Port Corporation and the Australian Maritime Safety Authority. The plan shall include

� measures to ensure compliance with national and international safety regimes;

� reporting procedures and organisational responsibilities in the event of incidents;

� contingency measures to minimise risks to human safety and the environment;

� specification of adequate resources to be held on ship and at berth to deal with crediblecontingencies; and

� a communication strategy to ensure effective and efficient liaison among shore-based andship-based emergency response teams.



May 2002xiv

Recommendation 11

Oil spill contingency plans for the construction dock and product-loading jetty shall be preparedby the proponent, within the overall context of the Darwin Port Corporation’s Oil SpillContingency Plan. The site-specific plan shall include

� an assessment of potential risks of spills of credible volumes;

� potential oil spill trajectories;

� maps of priority areas for protection (including aquaculture facilities);

� details for deployment of equipment to protect priority areas,

� demonstrated integration with the Darwin Port Corporation Plan;

� inventory of equipment for control and clean-up (including materials held at the jetty and/orconstruction dock for immediate clean-up of minor spills);

� strategies, actions and responsibilities for any clean-up; and

� a training and exercise strategy that includes relevant NT Government response personnel.


Recommendation 12

The proponent’s Environmental Management Program shall include specific measures tominimise loss and disturbance to remaining mangrove and dry rainforest habitat at WickhamPoint. This shall include measures to avoid unnecessary clearing and disturbance duringconstruction, measures to monitor and control weed and feral animal incursions, and measuresto minimise fire risks.

[ = Recommendation 11 in Assessment Report 24]

Recommendation 13

As part of the proponent’s Environmental Management Program, an Acid Sulfate SoilManagement Plan shall be prepared in consultation with relevant NT Government agencies.Sampling and analysis of potential acid sulfate soils shall be conducted as part of preparing thePlan. The Plan shall include monitoring of leachate from any soil or spoil retention areas andreclamation areas, and contingency measures in the event leachate is found to be excessivelyacidic.


Recommendation 14

In preparing the Environmental Management Program (EMP), the proponent shall include anyadditional measures for environmental protection and monitoring contained inrecommendations made by the Northern Territory and Commonwealth Governments withrespect to the proposal. The EMP shall be referred to relevant NT agencies and EnvironmentAustralia for review prior to finalisation, after which it shall become a public document. TheEMP shall form the basis for relevant approvals and licences issued under NT legislation.



May 2002xv

Recommendation 15

The proponent shall ensure that decommissioning is done according to the best environmentalstandards available at the time.

[ = Recommendation 20 of Assessment Report No. 24]


May 2002xvi

LIST OF RECOMMENDATIONS FROM ASSESSMENT OF 3 MTPA PROPOSAL (fromAssessment Report 24, February 1998)

Thirteen of the following twenty-one recommendations from Environmental Assessment Report 24(for the proponent’s earlier 3 MTPA LNG project) have also been included, in original or modifiedform, in the current Assessment Report for the 10 MTPA plant (Assessment Report 39). In thedevelopment of conditions for licences and permits, the current modified versions of earlierRecommendations, in addition to the two new Recommendations, should be considered.

Eight of the earlier Recommendations were not included in Assessment Report 39 and are indicated initalics in the following list. They should, however, also be implemented by the proponent indevelopment of the full-scale project (plant and sub-sea pipeline). The following ones have not beenincluded because they relate specifically to the sub-sea pipeline, which was not relevant to the currentproposal: Recommendations 4, 5, 9, 10 and 17.

Recommendations 12, 15 and 21 were not included in the current Assessment Report because theenvironmental protection measures they describe have been undertaken as commitments by theproponent in the PER or the proponent’s Response to Submissions for the 10 MTPA facility. Theseshould, however, also be considered in the setting of conditions for permits and licences.

Recommendation 1

The proponent shall ensure that the proposal is implemented in accordance with theenvironmental commitments and safeguards identified in the Darwin LNG Plant draftEnvironmental Impact Statement, as modified in the Supplement to the draft EIS and asrecommended in this assessment report.

Recommendation 2

In preparing the Environmental Management Plan (EMP) the proponent shall include anyadditional measures for environmental protection and monitoring contained inrecommendations made by the Commonwealth and Northern Territory Governments withrespect to the proposal. The EMP shall be referred to Environment Australia and relevant NTagencies for review prior to finalisation, after which it shall become a public document. TheEMP shall form the basis for any approvals and licences issued under the forthcoming WasteManagement and Pollution Control Act.

Recommendation 3

In the event that an expansion of the LNG Plant is proposed, the revised project design shall besubmitted to the NT Government for further assessment under the NT EnvironmentalAssessment Act.

Recommendation 4

The final route of the sub-sea pipeline and any associated surveys, studies and consultationsundertaken to determine the final alignment, shall be made available to relevant NT agencies forcomment. In particular, the proponent shall demonstrate that the route has been selected to avoid:� areas requiring blasting or substantial preparatory earthworks;� areas of recreational or conservation significance;� areas of significance to fishing activity;


May 2002xvii

� areas which may be inhabited by rare or endangered species;� protected maritime heritage areas;� shallow water depths, or shoals, where corals or other significant habitat may exist; and� marine Aboriginal sacred sites.

Recommendation 5

The proposed pipeline alignment survey shall be undertaken in close consultation with relevantNorthern Territory agencies. In the event that new wrecks or other historical materials are found,the proponent shall advise the Heritage Conservation Branch of the DLPE.

Recommendation 6

The proponent shall prepare an evaluation of the dredging, excavation and spoil disposaloptions. A dredging plan, addressing the environmental impacts, shall be submitted to the NTGovernment and Environment Australia for approval prior to commencement. The plan shallinclude proposed measures to ensure protection of the Channel Island coral assemblages. Thesemeasures shall include implementation of baseline studies, turbidity plume monitoring, areactive coral monitoring program (if required), and contingency measures to be implemented ifmonitoring indicates adverse impacts. Development of any monitoring and assessment programsassociated with the dredging plan shall be undertaken in consultation with the relevant NTGovernment agencies.

Recommendation 7

An Acid Sulphate Soil Management Plan and Monitoring Program shall be prepared inconsultation with relevant NT Government agencies. Sampling and analysis of potential acidsulphate soils should be conducted as part of preparing the plan. The plan shall includemonitoring of leachate from any soil or spoil retention areas and reclamation areas, andcontingency measures in the event leachate is found to be contaminated.

Recommendation 8

The proponent shall consult with relevant NT Government agencies on measures needed, andapplicable standards, for use of wastewater for land irrigation and/or as filtered dischargethrough mangroves, with a view to avoiding direct discharge to the waters of Darwin Harbour.If direct discharges are required, modelling of the effluent mixing zone shall be undertaken tothe satisfaction of relevant NT Government agencies to ensure that sufficient dilution will occurat the proposed discharge point to minimise impacts on nearby marine habitats.

Recommendation 9

The pipeline component of the Environmental Management Plan (EMP) shall address preparatoryrequirements for the pipeline (e.g. spanning support, rock dumping and stabilisation requirements)and measures to be implemented for the protection of the environment. The EMP shall also includemeasures to avoid and minimise impacts associated with laybarge operations including liquid andsolid waste management and disposal, anchoring systems, and control of turbidity associated withrock dumping.


May 2002xviii

Recommendation 10

The proponent shall advise all mariners, including commercial fishing operators and DPIF, of thedetailed pipeline construction timetable and route, when available, and undertake to negotiatechanges if necessary, to assist in minimising timing conflicts between pipeline laying and fishing.

Recommendation 11

The proponent shall include, as part of the EMP, specific measures to minimise loss anddisturbance to remaining mangrove and dry rainforest habitat at Wickham Point. This shallinclude measures to avoid unnecessary clearing and disturbance during construction, measuresto monitor and control weed and feral animal incursions, and measures to minimise fire risks.

Recommendation 12

The proponent shall ensure that on-going management of remaining vegetation and fauna habitatswill be undertaken, including monitoring of weeds and feral animals and prevention of fires. TheEMP shall include measures to mitigate any impacts in the event that adjacent vegetation appears tobe affected as a result of the operation of the plant. Vegetation management and mosquito breedingsites shall be included in the Site Environmental Audit.

Recommendation 13

The proponent shall consult with DLPE regarding preparation of the atmospheric emissionsinventory and any related monitoring. Both the inventory and any monitoring shall beimplemented to the satisfaction of the DLPE. The proponent shall verify, by monitoring forNO2, that there will be no exceedances, arising from atmospheric emissions, of the standardscontained in the proposed Ambient Air Quality NEPM. Monitoring procedures and datareporting must meet the NEPM requirements and Australian Standards. Monitoring points shallbe determined in consultation with DLPE.

Recommendation 14

The EMP shall include a section specifically addressing commitments and strategies aimed atreducing greenhouse gas emissions. This shall include, for example, provisions for regulargreenhouse gas audits, a process for continuous review of new technologies to identifyopportunities to reduce emissions, and benchmarking against other LNG facilities with a view toachieving international best practice in terms of CO2 emissions per unit of production.Opportunities for offsetting greenhouse gas emissions, including support for relevant researchshall also be addressed. The greenhouse gas strategy shall be provided to Environment Australiaand the DLPE for comment. Participation in the Greenhouse Challenge Program should also beexplored by the proponent.

Recommendation 15

The proponent shall ensure that relevant components of the Hazard and Risk Assessment coverecological risk as well as risk to human life. All components of the Hazard and Risk Assessment,including Emergency Response Plans, shall be provided to the NT Government for review beforefinalisation.


May 2002xix

Recommendation 16

Negotiations between the proponent, the RAAF, Darwin Airport authorities, Air ServicesAustralia and the Civil Aviation Authority to resolve outstanding concerns in regard to safetyinteractions between flaring and approaches to the north-south runway at the airport are noted.If negotiations indicate the potential for safety interactions, further analysis of hazards and risksto aircraft from flaring shall be required prior to a final decision on the type or nature of flaringto be used.

Recommendation 17

The proponent shall provide a Pipeline Rupture Management and Contingency Plan for the entirelength of pipeline, prior to its commissioning. This Plan should outline detailed measures tominimise risks of leakage and rupture, including external risks to the pipeline, and strategies andsystems to monitor, detect and repair leaks (including measures to detect and repair potential areasof leakage). Detailed contingency measures to ensure quick reaction to major incidents, includingmeasures to minimise environmental harm and environmental remediation if required, shall also beincluded. The plan shall be prepared to the satisfaction of Environment Australia, theCommonwealth Department of Primary Industries and Energy and the Northern Territory andWestern Australian Governments.

Recommendation 18

An emergency management plan addressing LNG carrier operations at sea, in Darwin Harbourand at berth shall be developed in consultation with relevant authorities such as the Darwin PortAuthority and Australian Maritime Safety Authority. The plan shall include matters such asmeasures to ensure compliance with national and international safety regimes, reportingprocedures and organisational responsibilities in the event of incidents, control of incidentresponses, contingency measures to minimise risks to human safety and the environment,minimum resources to be held on ship and at berth to deal with credible contingencies, andinteractions with shore based or other emergency response teams.

Recommendation 19

An oil spill contingency plan for the port facility shall be prepared by the proponent, within theoverall context of the Darwin Port Authority Oil Spill Contingency Plan. The site specific planshould include an assessment of potential risks of spills and credible volumes, potential oil spilltrajectories, maps of priority areas for protection including aquaculture facilities, deployment ofequipment to protect priority areas, integration with the Darwin Port Authority Plan, inventoryof equipment to deal with control and clean-up (including materials held at the wharf forimmediate clean-up of minor spills), strategies , actions and responsibilities for any clean-up, anda training and exercise regime (including with Northern Territory authorities).

Recommendation 20

The proponent shall ensure that decommissioning is carried out according to the bestenvironmental standards available at the time.

Recommendation 21

The proponent shall consult with the DLPE in the preparation, implementation and review of allmonitoring programs. The DLPE shall also be consulted regarding any mechanisms and actionsdeveloped as a response to monitoring results.


May 2002xx

FIGURES

1.1 Location Plan: Timor Sea (Bayu-Undan field) and Darwin Harbour

1.2 Major Components of Plant on Wickham Point

1.3 Layout of Facility

1.4 Phillips’ Optimised Cascade LNG Process

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00533244r011f1-1.dgn

10MTPA LNG PLANT AT WICKHAM POINT - PER

LOCATION PLAN

Figure 1.100533-244-562Job No.

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Phillips Petroleum Company Australia Pty Ltd

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00533244r011f1-2.dgn

10MTPA LNG PLANT AT WICKHAM POINT - PERFigure 1.2

MAJOR COMPONENTSOF APPROVED 3 MTPA LNG PROJECT

00533-244-562Job No.

Date Dec 01

R841Report No.


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EDGE OF WATERN.8614850E.702232


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00533-244-562Job No.

Report No.

Date

R841

Dec 01

10MTPA LNG PLANT AT WICKHAM POINT - PER

PROPOSED 10MTPA LNG FACILITY LAYOUT

Figure 1.3

ITEM No. DESCRIPTION QTY

FIRE WATER STORAGE TRAIN 1 PROCESS AREA

LEGEND

CONTROL ROOM

GUARD HOUSE

PAWA SUBSTATIONSWITCHGEAR YARD



LEGEND

CONTROL ROOM

GUARD HOUSE




LEGEND

CONTROL ROOM

GUARD HOUSE


MAINTENANCE SHOP AND LABMAINTENANCE SHOP AND LAB.

WAREHOUSE

ADMINISTRATION

DISTURBED AREA BOUNDARY

CONSTRUCTION / LAYDOWN AREA

TEMPORARY TELECOMMUNICATIONS SHELTER FLARE KNOCK-OUT DRUMS




TEMPORARY TELECOMMUNICATIONS SHELTER FLARE KNOCK-OUT DRUMSFREEHOLD BOUNDARYPIPELINE PULL ZONEPLANT MONUMENT 1

MARINE FLARE - ALTERNATE LOCATIONFUTURE SULPHUR RECEIVER

FIRE STATION & MEDICALCONDENSATE TANK / TRUCK LOADING

SULPHUR STORAGE

CONSTRUCTION DOCK REFRIGERANT STORAGE

JETTY MARINE FLARE

RECEIVER PIPELINE FROM BAYU-UNDAN

GROUND FLARE

TRAIN 2 PROCESS AREA - FUTURE

GROUND FLARE - ALTERNATE LOCATION

RECEIVER - ALTERNATE LOCATION


JETTY MARINE FLARE


GROUND FLARE





JETTY MARINE FLARE


GROUND FLARE




LNG STORAGE - TRAIN 2 - 160,000 M3 - FUTURE LNG STORAGE - TRAIN 1 - 100,000 M3

1 2 3 4 5 6 7 8 9

1 2 3 4 5 6 7 8 9

1 2 3 4 5 6 7 8 9

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22 23 24 25

27 28 29

22 23 24 25

27 28 29 30 31 32 33

10 11 12 13 14 15 16 17 18 1920 21

10 11 12 13 14 15 16 17 18 1920

10 11 12 13 14 15 16 17 18 1920

Mon

11

Mar

00533244r011f1-3.dgn


FIGURE 1.4PHILLIPS OPTIMISED CASCADE LNG PROCESS

Adapted from URS Report 00533-244 ‘Phillips 10 MTPA LNG Plant – Public Environment Report’


May 20021

1 INTRODUCTION AND BACKGROUND

This Report assesses the environmental impact of a proposal by Phillips Petroleum Company AustraliaP/L to construct a Liquefied Natural Gas (LNG) plant with a maximal output of 10 million tonnes perannum (MTPA) at Wickham Point in Darwin Harbour. Figure 1.1 indicates the location of the initialnatural gas source, the Bayu-Undan field, in the Timor Sea. Figures 1.2 and 1.3 indicate the locationof the LNG plant on Wickham Point and the layout of major components at the facility. Figure 1.4illustrates the Phillips’ Optimised Cascade LNG process.

This Environmental Assessment Report is based on a review of the Public Environmental Report(PER); comments from the public and Northern Territory Government agencies on the PER; andresponses by Phillips to these comments.

A list of respondents to the PER and issues raised in their submissions are provided in Appendix 1 and2, respectively. More detailed comments are listed Appendix 3.

1.1 Environmental Impact Assessment Process

One of the major objectives of environmental impact assessment is to fully define those elements ofthe environment that may be affected by a proposed development and to determine the significance,risks and consequences of the potential impacts of the proposal. The potential impacts are consideredat both local and regional levels.

This report evaluates the adequacy of undertakings and environmental safeguards proposed by Phillipsto avoid or mitigate the potential impacts identified in the assessment process. The safeguards may beimplemented at various levels within the planning framework of a project and include (among otherapproaches)

� Design and layout of buildings and other infrastructure on site;� Management of construction activities; and� Management of processes used in operations at the facility (e.g. inputs and outputs).

A list of undertakings made by the proponent in the PER and in their “Response to Submissions” fromthe public and NT Government is provided in Appendix 4. Additional safeguards are recommended inthis Assessment Report where appropriate.

The contents of this Assessment Report form the basis of advice to the NT Minister for theEnvironment on the environmental issues associated with the project.

1.2 Environmental Impact Assessment History

In 1997, Phillips Oil Company Australia submitted to the NT Government a proposal to construct aLiquefied Natural Gas (LNG) facility at Wickham Point (on the Wickham Point Peninsula, betweenEast Arm and Middle Arm) in Darwin Harbour. The proposed facility comprised a single train plant toproduce LNG at a maximal rate of 3 million tonnes per annum (MTPA) from gas transported from theBayu-Undan field (in the Timor Sea) to Wickham Point via a sub-sea pipeline. (A “train” is aproduction pathway and related infrastructure, having its own process area at the facility.)

The proposed project included

� a sub-sea pipeline;� a land-based facility for liquefaction of natural gas and storage of LNG;


May 20022

� marine loading facilities; and� a dedicated fleet of ships to transport LNG product.

The proposal went through a detailed Environmental Impact Assessment process, at the level of anEnvironmental Impact Statement (EIS) and received approval from Commonwealth and NorthernTerritory Environment Ministers in early 1998. The NT Government analysis of the project,comments and Supplement formed the basis of the Territory’s Environmental Assessment Report 24.

In May 2001, Phillips submitted a Notice of Intent (NOI) to the NT Department of Lands, Planningand Environment (now Department of Infrastructure, Planning and Environment) for a proposed LNGfacility of up to 10 MTPA at the same site. The expansion would allow Phillips to access and processgas from other fields in addition to their Bayu-Undan field, e.g. the Greater Sunrise field which has a“proven plus probable” 9.2 trillion cubic feet of gas (approximately 2.7x larger than the Bayu-Undanfield).

Phillips has indicated that the 10 MTPA proposal comprises the optimal-sized facility at WickhamPoint and any material expansion in the future, other than de-bottlenecking, would be unlikely. (“De-bottlenecking” involves the incorporation of additional or more efficient components or activities toincrease output, e.g. by using more powerful pumps or adding additional storage tanks or pipelines.)

In June 2001, the Minister for Lands, Planning and Environment determined that the new proposalwould be assessed at the level of a Public Environmental Report. Draft guidelines covering issues tobe addressed in the PER were subject to public review from 21 July – 3 August 2001.

Subsequent to the public review of the draft Guidelines, Phillips referred the proposed expansion tothe Commonwealth for a determination under the Environment Protection and BiodiversityConservation Act (EPBC Act) 1999. On September 20, 2002, the Commonwealth determined that itwould review the project under the Environmental Protection (Impact of Proposals) Act 1974 and notthe EPBC Act, as the original assessment was done under the former Act. Once the Commonwealthmade its determination, the NT Minister for the Environment issued final guidelines (31 October).

In March 2002, Phillips submitted its PER for the 10 MTPA plant (comprising two trains, each with amaximal output of 5 MTPA).

The PER was placed on public review for 5 weeks, from 18 March to 19 April 2002. It was alsocirculated to NT Government advisory bodies for review and comment. Eight public submissionswere received within the review period. Comments from NT Government agencies were consolidatedinto one submission and forwarded, with the public submissions, to the proponent and EnvironmentAustralia at the close of the public review period.

The proponent prepared a “Response to Submissions,” addressing the issues raised by the public andNT Government. This Response was received by the Office of Environment and Heritage on 8 May2002 and taken into account in the preparation of this Assessment Report. A copy was also forwardedto Environment Australia, which will prepare its own report under the Environment Protection (Impactof Proposals) Act 1974.


May 20023

2 THE PROPOSAL

Detailed descriptions of the major components of the proposal are presented in the PER. Thefollowing is a short summary.

2.1 Objectives of the Expanded Proposal

The objective of the entire proposal is to transport natural gas from the Timor Sea, via a sub-seapipeline, to Wickham Point for processing into liquefied natural gas (LNG). The original proposal fora 3 million tonnes per annum (3 MTPA) was based on using a single processing “train” to process gasjust from the Bayu-Undan field, and this proposal was approved by both the Commonwealth and NTGovernments.

Phillips, however, wishes to expand the scope of the original proposal to a 10 MTPA plant (with two5 MTPA trains) that can capture and process gas from additional offshore fields, e.g. the GreaterSunrise field in the Timor Sea.

2.2 Alternatives to the Proposal

As the 3 MTPA proposal for Wickham Point had previously been approved, the proponent did not re-consider alternative sites.

Regarding alternatives for expansion at Wickham Point, however, the proponent had previouslydeveloped a scenario to allow for future expansion to a 9 MTPA plant (Supplement to the Draft EIS,Dames and Moore 1998a), involving three 3 MTPA trains.

The PER for a 10 MTPA plant indicates that SO2 emissions for a facility of this size wouldsubstantially exceed that predicted for the 9 MTPA plant, because of higher sulphur content in feedgas from other offshore reserves and because, in the earlier proposal, volumes of SO2 vented to theatmosphere were not fully taken into account.

Most other emissions (including greenhouse gases) and volumes of solid waste would, however, beless for the 10 MTPA plant than projected for the 9 MTPA plant. These decreases relate to the use ofonly two trains (each with a maximal output of 5 MTPA) instead of three trains (each 3 MTPA at fullcapacity) and integration of new technologies (e.g. waste heat and vapour recovery systems, and moreefficient turbines).

In addition to the desirable environmental outcomes above, “economies of scale” issues would resultin significant financial savings to the proponent were they to construct a two-train rather than a three-train facility.

Further, the proponent has developed a standard technology for construction of (modular)5 MTPA facilities that use its “Optimised Cascade LNG Process.”

For all of these reasons, the proponent considers that the 10 MTPA proposal represents the optimal-sized LNG facility for the Wickham Point site and it is unlikely that the proponent would consider anymaterial expansion of such a facility in the future, other than for “de-bottlenecking improvements.”


May 20024

2.3 Major Components of the Proposal

Figure 1.3 shows the layout of major components of the proposed 10 MTPA facility.

2.3.1 Metering Station

An inlet metering station (south of the main plant area) will receive natural gas from the offshorepipeline, measure various aspects of the gas (for use in pipeline monitoring and gas sales accounting)and condition the gas for delivery to the LNG plant or to domestic markets.

2.3.2 LNG Plant

The proposed facility will include a two-train LNG plant of up to 10 MTPA capacity with thefollowing major components:

� Gas processing facilities to remove impurities and refrigerate the natural gas;

� Product storage tanks; and

� Plant infrastructure and utilities.

Initial site preparation is expected to start in late 2002. Construction of the first process train (up to5 MTPA) is expected to commence in early 2003 and be completed by early 2006. Construction ofthe second LNG process train, if additional gas supply arrangements can be secured, is expected tocommence in late 2003 and be completed in late 2006.

The operational life of the project is expected to be 20-25 years (with extension subject to discoveryand capture of additional reserves of natural gas).

Production of LNG will involve

� removal of components within the gas stream that are detrimental to the natural gasliquefaction process (e.g. carbon dioxide, hydrogen sulfide, mercury and water);

� refrigeration to liquefy the gas; and

� storage prior to loading into tankers for export.

Approximately 88.6 ha of land at Wickham Point will be cleared to accommodate the plant facilities.(Figure 2 shows the layout of major components).

2.3.3 LNG Ship-loading Facilities

A loading jetty will be constructed on the west side of Wickham Point (in Middle Arm of DarwinHarbour) to transfer LNG (and some condensate) to vessels for export. The jetty will comprise a925 m rock groyne abutting the shoreline, with an adjoining open-piled trestle structure,approximately 500 m long, leading to a pile-supported loading dock (36 m x 16 m). Up to 100,000 m3

of sea-bed sediment may have to be dredged at the head of the jetty, to provide at least a 600 mdiameter turning basin for vessels and a 400 m x 70 m “berthing pocket.”

2.3.4 Construction Dock

A construction dock will be built on the north-east side of Wickham Point to receive heavy equipment,pre-fabricated process modules and possibly plant personnel. The dock will include a 20 m-wide rockgroyne extending approximately 470 m into East Arm and a rock-fill dock (approximately 50 m x 30m). A 200 m x 40 m berthing pocket and a 1-km long approach channel (70 m wide and dredged to- 6 m AHD) will be provided.


May 20025

2.3.5 LNG Tankers

LNG will be exported from Wickham Point via purpose-built tankers, all of double-hull design. Theyare expected to have a draught of 11.5 m and be between 250 and 290 m in length, with a capacity ofup to 145,000 m3 of LNG. If running at the full 10 MTPA capacity, vessels will arrive every 2-3 daysfor loading and export. Turnaround time for vessels will be approximately 24 hrs, with product-loading expected to take approximately 14 hrs.

2.4 Key Differences between the 3 MTPA and 10 MTPA Proposals

The major impacts of the proposed 10 MTPA facility compared to the approved 3 MTPA facility willresult from the increased capacity of the plant and will be as follows:

� Increased area of ground disturbance, from 66.8 ha to 88.3 ha;

� Increased demand for power generation, from 18.2 MW to 48.4 MW;

� Increased operating work-force, from 75 to 120 personnel;

� Increased demand for process water, from 6 to 12 m3/hr;

� Increased volumes of waste-water requiring treatment/disposal, from 4.5 to 11 m3/hr;

� Increased volume of storage tank hydro-test water discharged prior to plant start-up;

� Increased volume of solid and semi-liquid waste generated and requiring disposal (from 143,050to 242,600 kg/yr);

� Increased risk to the public and the environment from greater volumes of LNG storage tanks (from190,000 m3 to 360,000 m3);

� Increased risk to the public and the environment from increased shipping movements, from 78visits to approximately 160 visits per year, and the navigation risk associated with using largervessels; and

� Increased atmospheric and greenhouse gas emissions (especially CO2, which, at full plantcapacity, will be generated at a rate of 4.5 MTPA compared to 1.7 MTPA).

The PER describes two other key modifications for the 10 MTPA plant:

� The new facility will not produce commercial quantities of propane or butane (LPG) for export, asproposed in the 3 MTPA EIS, as the feed stock gas will be processed offshore to remove LPGs.The LPG storage tanks (at Wickham Point) in the earlier proposal have therefore been eliminatedfrom the current design. The only other saleable product will be much smaller volumes ofstabilised condensate than those associated with the 3 MTPA proposal, as most of the condensatewill also be removed offshore from the natural gas extracted from the field.

� Instead of the elevated main flare included in the 3 MTPA design, a large ground flare will beused for the 10 MTPA plant, and the flare has been relocated to the south of the plant site. Thischange was made to accommodate a proposed future road transport corridor from Darwin toPalmerston and an air-traffic corridor for aircraft approaching Darwin Airport.


May 20026

3 REGIONAL SETTING: DARWIN AND DARWIN HARBOUR

The information in this section is largely a summary of that presented in the EnvironmentalAssessment Report (No. 24) for the proponent’s original EIS; however, the proponent updated theenvironmental descriptions on the basis of review of recent literature and consultations withspecialists.

As per the Guidelines issued to the proponent, the focus is on the main features of the environmentthat could be affected by the expanded project, particularly in relation to the Darwin air-shed andcatchment of Darwin Harbour. The offshore region (which is relevant to the pipeline to the Bayu-Undan gas field in the Timor Sea) is not considered here, as this component of the proposal isunchanged and was approved as an outcome of the earlier assessment of the 3 MTPA project.

3.1 Physical

Darwin Harbour, with an area of about 500 km2, is a large ria system, or drowned river valley, formedby postglacial marine flooding of a dissected plateau. In its southern and south-eastern portions, theharbour has three main components: East, West and Middle Arms which merge at their mouths toform the central portion of the Harbour, along with the smaller Woods Inlet, before joining the opensea. Freshwater inflow to the Harbour occurs primarily from January to April, when estuarineconditions prevail in all areas (Hanley 1988).

Over the 6-8,000 years since Darwin Harbour was formed by rising sea levels, erosion from theadjoining terrestrial environment has carried substantial quantities of sediment into the harbour. Thissediment now forms much of the intertidal flats that cover the pre-flooding bedrock. The sea-bed ofDarwin Harbour is dominated by gravel. The centre of the Harbour comprises a scour zone where thehard pavement substrate is covered by only a thin layer of sediment, grading into terrigenous sandoffshore from the tip of Wickham Point. The intertidal area off the point itself comprises large sandand mud flats.

Phillips proposes to locate the LNG plant on Wickham Point, toward the sea-ward end of WickhamPoint Peninsula between East Arm and Middle Arm. Both arms are the estuaries of rivers whichduring the wet season drain much of the hinterland behind Darwin and Palmerston. The ElizabethRiver flows into East Arm; the Darwin and Blackmore Rivers flow into Haycock Reach which thenflows into Middle Arm.

Most of the Harbour is less than 10 m in depth; however, a channel with depths exceeding 20 mextends in a south-easterly direction from the mouth of the Harbour toward the confluence of Middleand East Arms. The channel continues into East Arm at water depths greater than 15 m. A slightlydeeper channel extends into Middle Arm. The tidal range in Darwin Harbour reaches 8 m.

Wickham Point is on the north-west tip of Wickham Point Peninsula. This peninsula is characterised bytwo small ‘islands’ of terrestrial vegetation surrounded by intertidal mangrove forests that are partially orcompletely inundated by water at high tide. For the purposes of this report, Wickham Point refers to thewestern-most island. This is the proposed site for the LNG plant.


May 20027

3.2 Areas with Significant Conservation Values and/or Management Issues

3.2.1 Biological

Marine/Estuarine (subtidal and intertidal habitats)

Darwin Harbour has a diverse assemblage of species typical of the Indo-west Pacific Biogeographicalprovince. Protected species in the Harbour include turtles, sea-snakes, dugongs and dolphins, whichare all listed under the Commonwealth Environment Protection and Biological Conservation Act1999.

Coral communities occur where the substrate is rocky in the lower intertidal and shallow subtidalzones. The intertidal platform between Channel Island and the mainland is listed on the Register ofthe National Estate and has been declared a Heritage Place under the Northern Territory HeritageConservation Act 1991. This declaration was based on the presence of an unusually diverse coralcommunity.

Wickham Point is surrounded by an extensive mangrove community, typical of the majority of theshoreline of Darwin Harbour. Other intertidal communities include rocky shores and pavements, sandbeaches and sand and mud flats. The Darwin Harbour wetlands (mangroves) are listed as an“Indicative Place” nominated for inclusion on the Register of the National Estate.

Other areas of conservation significance include the Charles Darwin National Park, Casuarina CoastalReserve, Blackmore River Conservation Reserve, East Point Aquatic Life Reserve and Doctors GullyAquatic Life Reserve.

Terrestrial

The terrestrial flora of the Wickham Point islands is dominated by dry rainforest (also known as“monsoon vine thicket”) with limited areas of paperbark-dominated woodlands. No rare or endangeredfloral species has been recorded at Wickham Point; however, the dry rainforest is of regionalconservation interest.

The fauna, particularly birds, is diverse, with a number of migratory species known in the area;however, none of these species is regarded as threatened in the Darwin region. Substantial populationsof medium and large sized mammals such as Northern Brown Bandicoot, Northern Brushtail Possumand Agile Wallaby on Wickham Point occur in the area. None of these species is rare or endangered.The area has not been recently burned, and introduced weeds and feral animals are uncommon. Theundisturbed nature of the “islands” makes them of conservation interest.

3.2.2 Cultural

Nine archaeological sites were identified on Wickham Point during the original environmentalassessment, most located either within or immediately adjacent to the proposed plant area: six areprehistoric shell middens; two are historic sites dating from World War II; and one is the remains ofthe “Mud Island” leprosarium. A further five shell middens, and a WWII heritage site, were recentlydiscovered and are currently subject to complete heritage surveys in consultation with the Office ofEnvironment and Heritage.

No Aboriginal burial grounds are known on Wickham Point, but it is likely that burials did occur nearthe leprosarium site and possibly in shell middens in the area. The leprosarium is located north of theLNG plant site.


May 20028

3.2.3 Socio-economic

Darwin is the major city along Australia’s northern coastline and the capital of the Northern Territory.The total population of the Darwin region (including Darwin, Palmerston and Litchfield Shire) isabout 107,000. As a major city, Darwin has a wide variety of infrastructure, including port facilities atFrances Bay and in East Arm, an airport, national highways to other cities, and other facilities neededfor the LNG plant and its personnel. The nearest community to Wickham Point by highway isPalmerston (population about 25,000), approximately 25 km by road to the east.

Wickham Point is considered a significant place by the Larrakia and other Aboriginal people livingaround Darwin Harbour. In 1999 an agreement was reached with various Native Title parties and theNorthern Land Council to resolve native title and Aboriginal land rights claims previously lodged forthe area.

Darwin Harbour is widely used for a variety of activities, including recreational fishing, scuba diving,boating and aquaculture. Some of these activities occur within 5 km of the proposed LNG site.

The proposed Wickham Point site lies along the flight path to the runway at Darwin’s regional airportused by smaller private and commercial airplanes. Submarine telecommunication and power cablescross the Harbour from Darwin to Mandorah; therefore, anchoring is prohibited in these areas.


May 20029

4 ENVIRONMENTAL IMPACT ASSESSMENT

4.1 Introduction

The main purpose of this Environmental Assessment Report is to determine if the proposed projectcan proceed without unacceptable environmental impacts. It does this by identifying all relevantpotential environmental impacts and evaluating the feasibility and likely effectiveness ofenvironmental safeguards put forth by the proponent. Where the proposed safeguards were consideredincomplete or inadequate, or for safeguards that are particularly crucial, this Assessment Report makesrecommendations to complete or emphasise the safeguards and commitments made by the proponent.

The environmental acceptability of the project is based on consideration of the following, from thePER:

� adequacy of information outlining the proposal (particularly which structures or activities arelikely to impact the environment);

� adequacy of information on the existing environment (particularly environmental sensitivities);

� adequacy of information on the range and extent of potential impacts; and

� adequacy of the proposed safeguards to avoid or mitigate potential impacts.

Conclusions are then based on comments from review of the PER by relevant government agenciesand the public, and responses from the proponent to these comments.

The outcome of the environmental impact assessment for this proposal is that the NT Governmentbelieves that the project can be implemented without unacceptable environmental impacts. Thisoutcome is dependent on the proponent implementing the environmental safeguards identified in itsPER in addition to recommended measures for environmental management presented in thisEnvironmental Assessment Report.

Because minor and non-substantial changes may be made to the design and specifications presented inthe PER, some degree of flexibility is desirable and will be necessary for adapting the environmentalsafeguards defined in the PER and this Assessment Report. Where it can be shown that such changesare not likely to have a significant impact on the environment, an adequate level of environmentalprotection may still be achieved by the following recommendations, modifications to theserecommendations or by conditions attached to relevant statutory approvals for these modifications.

4.2 Integration of recommendations from assessments for the EIS and PER

The remainder of this section (Section 4) provides the major outcomes of the environmental impactassessment for the proposed expansion of Phillips’ original 3 MTPA plant to a 10 MTPA facility.Because this proposal does not involve changes to either the proposed sub-sea pipeline or the accessroad, these elements will not be discussed here. The recommendations in the previous AssessmentReport (No. 24) that relate to these components are, however, to be considered current and are to beimplemented as written.

As presented in Section 2.4 of this Assessment Report, the expansion will have an increased level ofpotential or anticipated impact for a range of environmental effects identified during the earlierassessment of the 3 MTPA plant.


May 200210

Some of the recommendations from the previous Assessment Report (No. 24, 1998) are still adequateand appropriate for the expanded proposal; however, some need modification to cover a change inenvironmental risk. Further, the current assessment has also resulted in several additionalrecommendations.

To include all relevant outcomes from the environmental assessment of the EIS in addition to thosefrom the PER, and to present them in a logical sequence, easily cross-referenced to the previousAssessment Report, the following approach has been taken for the remainder of Section 4:

� Description of environmental impacts and proposed safeguards/mitigation will follow fairlyclosely the order in which they were introduced in the PER;

� Additional potential impacts identified from the review of the PER by the public and NTGovernment agencies and from the previous Assessment Report will be added to the most closely-related issue in the PER; and

� Recommendation number will follow this order but be cross-referenced to the previousrecommendation number in Assessment Report 24.

Each recommendation (in bold) is preceded by text that identifies concerns, suggestions andundertakings associated with the project. For this reason, the recommendations should not beconsidered in isolation.

Subject to decisions that permit the project to proceed, the primary recommendation of this assessmentis

Recommendation 1

The proponent shall ensure that the proposal is implemented in accordance with theenvironmental commitments and safeguards

� identified in the Darwin 10 MTPA LNG Facility Public Environmental Report (PER) and asmodified in the proponent’s Response to Submissions from the public and NT Governmentagencies that reviewed the PER; and

� as recommended in this Assessment Report (No. 39) which includes relevantrecommendations from the previous Assessment Report (No. 24).

[~ Recommendation 1 in Assessment Report 24]

4.3 Issues Raised in Submissions

A list of respondents to the PER and issues raised in their submissions are presented in Appendices 1 –3.

The major environmental issues identified in review of the proposed construction and operation of the10 MTPA LNG plant at Wickham Point are as follows and are in a similar order to those presented inthe PER:

1. Atmospheric emissions2. Greenhouse emissions3. Heat emissions (flaring)4. Waste-water discharges5. Solid and semi-liquid waste disposal6. Dredging and disposal of spoil7. Risks from shipping


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8. Hazard and risk assessment (public and environmental)9. Ecological impacts10. Noise11. Work health issues (including biting insects)12. Impacts on visual amenity13. Socio-economic impacts14. Cultural impacts15. Other potential impacts (including erosion)16. Sustainability.

The remainder of this section (Section 4) identifies the issues raised in submissions on the PER andpresents commitments made by the proponent (in the PER or in its Response to Submissions) to avoidor mitigate potential or anticipated environmental impacts. Recommendations to strengthen theproponent’s commitments or to provide safeguards that may not have been provided by the proponentare also presented.

4.3.1 Issues Outside the Scope of this Environmental Impact Assessment

Plant location

Several submissions raised the issue of location of the plant within Darwin Harbour. This issue is,however, outside the scope of the PER, as approval has already been given to the proponent to developa 3 MTPA facility at this site. The current proposal is an extension of that original proposal.

Planning, zoning and Native Title

Other submissions raised issues relating to strategic planning and zoning which are also outside thescope of the current review; however, the NT Government is addressing these on a number of fronts.For example, completion of the Litchfield Planning Concepts and Land Use Objectives (DLPE 2001a)will identify the land at Wickham Point for industrial purposes taking account of the need to protectenvironmental values particularly of the mangroves and the Harbour. Amendments to the LitchfieldArea Plan, as a consequence of the Planning Concepts and Land Use Objectives, will identify specificzones to accommodate industrial development.

The proponent will lodge an appropriate Development Application for this site to meet requirementsof the expanded 10 MTPA facility.

The northern tip of Wickham Point (within Section 1861) is not affected by the proposed LNG plant;however, because of its significant heritage value (including WWII and leprosarium ruins), onesubmission indicated that the area should be managed for conservation purposes as a buffer to theproposed development.

The proponent has indicated its availability to liaise with DIPE further on this issue, however, it has noauthority to control access to this location.

The PER details the specific area within Section 1861 wherein plant construction and operationalactivities will be conducted. As not all land within this Section will be disturbed, the proponentsuggests that the remaining lands will comprise a de-facto conservation area.

In addition to completing plans for Litchfield, the Government is developing a Darwin HarbourStrategic Plan for Beneficial Uses. This will contain strategies to plan for and manage competingactivities and interests in the Darwin Harbour catchment, with the aim of maintaining the Harbour’sdeclared Beneficial Uses: protection of aquatic ecosystems, recreational water quality and aesthetics.


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The expanded development is within the boundaries of the draft lease developed in 1999 and hasNative Title clearance; therefore, there is no impediment to proceeding with a revised offer and lease,taking into account the proposed expansion.

Future Expansion (beyond 10 MTPA facility)

As noted in Sections 1 and 2 of this Assessment Report, the proponent is unlikely to pursue anymaterial expansion of the 10 MTPA facility (other than for “de-bottlenecking) in the future, becausethe proponent considers a 10 MTPA plant to represent the optimal-sized facility for Wickham Point.The proponent, however, acknowledges throughout the PER that any proposed expansion will besubject to further assessment under the NT Environmental Assessment Act.

Recommendation 2

If expansion of the 10 MTPA plant is proposed, the revised project design shall be submitted tothe NT Government for further assessment under the NT Environmental Assessment Act 1982.


4.4 Further Impact Assessment Studies Relating to Proposed Expansion

Since the previous environmental assessment, the following studies have been done to update baselineinformation for the existing environment and to assess the significance of potential impacts associatedwith the expanded project:

� Updated atmospheric dispersion modelling (incorporating predicted increases in emissions andcumulative impacts with emissions from Channel Island Power Station);

� Greenhouse gas emissions assessment (addressing increased production and options formitigation);

� Assessment of heat envelope from flares on air traffic (incorporating change to a main groundflare instead of elevated flares);

� Wastewater discharge analysis (addressing increased volumes and feasibility of on-site irrigationwith treated effluent);

� Analysis of solid and semi-liquid waste management (including capacity of existing infrastructureand services to handle increased production of wastes);

� Updated noise modelling (taking into account increased construction period);

� Revised comparative visual impact assessment (addressing increased size of storage tanks butdecrease in impact from ground vs. elevated main flare);

� Revised hazard analysis and public risk assessment (incorporating two process trains vs. one;greater LNG storage capacity; and more frequent shipping movements);

� Assessment of dredging and spoil disposal options and impacts (accounting for anticipateddecreased requirement for dredging for off-loading jetty);

� Updated ecological impact assessment (addressing increased amount of dry rainforest to beremoved);

� Socio-economic and cultural impact assessment (incorporating new archaeological finds) ; and

� Assessment of the sustainability of the project (incorporating environmental, social and economicaspects).


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4.5 Atmospheric Emissions

4.5.1 Existing Environment and Potential Impact on Air Quality

The PER acknowledges that Channel Island Power Station is currently the main source of emissions toair in the vicinity of the proposed LNG plant; however, emission levels are generally low and have nodetrimental effect on regional air quality.

The PER presents results from a revised air modelling study (Appendix C), including potentialcumulative effects of emissions from the proposed 10 MTPA LNG plant and those from the ChannelIsland Power Station. These showed that predicted worst-case concentrations of all pollutants wouldmeet accepted National Environment Protection Measures (NEPM) standards, with no adverse impactson the residents of Darwin; however, these predictions need to be verified, especially for oxides ofnitrogen (NOx) the pollutant most likely to approach ambient limits.

Recommendation 3

The proponent shall quantify the major emission sources during commissioning of the project,by periodic emission testing programs. Dependent on the results of this verification process, theproponent will establish a monitoring system for oxides of nitrogen (NOx) from key emissionsources at the facility and shall verify that standards contained in the National EnvironmentProtection Measure (NEPM) for Ambient Air Quality are not exceeded.

Procedures for monitoring and reporting shall be developed in consultation with the Office ofEnvironment and Heritage and shall meet relevant NEPM requirements and AustralianStandards.

[~ Recommendation 13 in Assessment Report 24]

4.5.2 Adequacy of Modelling

The proponent used a regulatory air dispersion model to predict the behaviour and impact of emissionsfrom the facility.

Several submissions on the PER questioned the validity of results from simulations, because the modeldid not integrate data on humidity and precipitation. The proponent has responded by explaining thatthese data cannot be directly input into the model and that the regional meteorological conditionsneeded for simulations are better described by wind speed and direction, atmospheric stability, mixingdepth, temperature profiles and topographical influences of the surrounding terrain.

The proponent explains further that by not taking into account the scavenging effects of wetdeposition, it has provided a more conservative (i.e. slightly greater) estimate of ground-levelconcentrations of pollutants over the regional air-shed. As the predicted acid-forming compounds (inparticular, SO2) will be well below those concentrations that are likely to lead to acid rain, inclusion ofscavenging effects for wet deposition is not warranted.

4.5.3 Sulphur Dioxide (SO2)

The original 3 MTPA proposal indicated that hydrogen sulphide (H2S) from the amine treatment unitwould be vented to the atmosphere or partially combusted. In the current proposal, an acid gasincinerator has been provided to combust all H2S removed; therefore SO2 emissions are greater than inthe original proposal.

The ultimate concentration of H2S in the gas stream coming to the Wickham Point plant will remainuncertain prior to the commencement of Bayu-Undan production activities and could change over the


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life of the Bayu-Undan field or as gas from additional fields are added to the influent gas stream to theLNG Plant. The concern is that the H2S concentration (3-15 ppm) could be high enough to precludeits venting both for safety reasons or to continually meet ground level concentration standards of 0.2-2.0 �g/m3 (30 min average) defined by WHO (1999) Guidelines for odour threshold and NHMRC(1986) discharge limit of 5 mg/m3. In consideration of the regulatory and health considerations, theproponent included the acid gas incinerator and calculated emissions based on the maximum designpremise concentration for H2S.

The air dispersion modelling for the PER showed that maximum ground level concentrations of SO2are predicted to be approximately 0.0004 parts per million (or 0.4 ppb) on an annual averaging period,which represents only 2% of the current acceptable ambient standard in the National EnvironmentProtection Measure (Air NEPM). On the basis of this modelling, there is little justification forcontinuous SO2 monitoring.

One hundred thirty (130) tonnes per year is the lowest potential SO2 emissions given the currentestimated H2S concentration in the feed gas. Information in the PER suggests that SO2 emissionscould potentially be as high as 706 tonnes per year if the facility produces LNG at the maximal rate,i.e. 10 MTPA (based on a concentration of H2S of 15 ppm). The PER indicates that the H2Sconcentration of the feed-gas has the potential to vary because of differing quality of gas from otherfields.

The potential for the feed gas H2S to increase up to 15 ppm was put forth to address higher emissionsscenarios that may be seen as gas from different fields are introduced to the LNG plant. If H2Sincreased from 3 to 15 ppm, then ground level concentration of SO2 would be expected to increase bya similar factor. Even if the H2S concentration is 15 ppm, the maximum ground level concentrationwill be 0.002 �g/m3, which is less than 10% of the NEPM standard. On the basis of this modelling, themaximum ground level concentrations of SO2 for the higher feed gas H2S should still be acceptable.

4.5.4 Nitrogen Oxides (NOx)

Ground-level concentrations of NOX arising from the operation of the proposed LNG plant (in additionto the Channel Island Power Station) are not predicted to significantly impact regional air quality. Anyproposals that may substantially increase NOX emissions from the LNG plant (e.g. resulting fromupgrading or expansion) will require further assessment.

The feed gas from Bayu-Undan has a nitrogen content of approximately 4%. The PER indicates thatthe majority of this nitrogen must be removed to meet LNG specifications, and it is added to the fuelsystem used by the gas turbines for the refrigerant compressors. Combustion of this “lean” (or highnitrogen-content fuel) reduces NOx by approximately 30.1% compared to emissions for the sameturbine using other fuel sources with a higher methane content.

4.5.5 Potential Generation of “Acid Rain” (from sulphur dioxide or nitrogen oxides)

Atmospheric deposition is the process whereby airborne particles and gases are deposited on theearth's surface and may arise from both natural and anthropogenic sources. Wet deposition is thefraction of atmospheric deposition contained in precipitation, while dry deposition (the remainder) is


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the fraction deposited in dry weather through such processes as settling, impaction, and adsorption.Acidic wet deposition is called acid precipitation (or acid rain), from secondary pollutants that formfrom the oxidation of nitrogen oxides (NOX) or sulphur dioxide (SO2) gases that are released into theatmosphere. Impacts from acidic deposition are largely witnessed in areas such as North America andEuropean countries where high concentrations of these pollutants are elevated by anthropogenicsources.

Of the pollutants that are of primary relevance to acidic deposition, emissions of SO2 are responsiblefor 60-70 % of the acid deposition that occurs globally. As noted previously, dispersion modelling hasdemonstrated that maximum annual SO2 concentrations from the LNG plant are predicted to be only0.0004 ppb, which represents 2% of the NEPM standard or 1% of the World Bank Guidelines. Advicefrom the Ambient Air Quality Final Impact Statement for the National Environment ProtectionMeasure indicates that compliance with the 0.02 ppm annual average should ensure that any effects ofacid deposition remain minor.

In addition, the typically high pH (low acidity) conditions of Darwin Harbour, reported to range from8.3 to 8.7 by DIPE (Padovan 1997), and the significant buffering capacity of estuarine waters,suggests there is little potential for acidic effects on waterways in the Darwin region to occur withminimal SO2 released from the proposed plant.

4.5.6 Potential Impacts on Public Health

The standards of the Ambient Air Quality NEPM have been selected by all Australian jurisdictions toensure the protection of human health and well-being, as a result of reviewing the latestepidemiological studies of known health end points from atmospheric pollutants. Long-term (chronic)health effects of NOx (modelled to be only 4.3% of the annual ambient standard, from cumulativeemissions from the power station and the proposed LNG plant) are therefore unlikely, as the proponenthas indicated that the facility will comply with these standards.

(The proponent acknowledges a typographical error in the PER which reported higher NOx annualconcentrations than was actually modelled: the correct maximum predicted concentration of NOx is0.0013 ppm (4.3 % of the NEPM), instead of 0.013 ppm as reported in Table 4.3 of the PER.)

4.5.7 Particulates

Regarding levels of particulates, especially under dry season conditions, the proponent indicated thatthe 10 MTPA LNG facility will be a very minor contributor to ambient particle levels in the Darwinregion. The proposal is anticipated to release 537 tonnes per annum (TPA) of particulates, withdispersion modelling showing that maximum concentrations of PM10 from the plant alone would bein the order of only 2.9 �g/m3 (or < 6% of the NEPM standard). (PM10 is particulate matter, in airemissions, that is < 10 microns in size.)

Modelling did not include contributions of PM10 from bushfires; however, the Darwin Air EmissionInventory (DLPE 2001b) indicates that annual emissions of PM10 are in the order of 6,200 tonnes,with 91% or 5,640 tonnes of the emission from bushfires occurring during the dry season.

In contrast, the proposed 10 MTPA LNG Plant is anticipated to release 537 TPA of particulates, notnecessarily solely PM10. Half (or 268 tonnes) would be released over the period of the dry season.This represents < 5 % of the bushfire contribution over the dry season.


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The proponent notes that the 2001 Air NEPM Monitoring Plan for the NT (DIPE, May 2001)demonstrates benchmark PM10 data collected at Berrimah between February and December 2000typically ranging from 20-40 �g/m3 (24 hour average) during the dry season, and exceeding the 50�g/m3 NEPM standard on a number of occasions due to bushfire smoke. It is therefore considered thatthe low 2.9 �g/m3 concentration from the LNG facility would not influence the existing particulatelevels attributable to fires in the region. The proponent recognises that the management of particulatesfrom bushfire smoke or fuel reduction burning is the primary air quality issue in the NorthernTerritory, as stated in the Final Impact Statement for the Air NEPM (NEPC 1998).

4.5.8 Odours

The proponent indicated in its Response to Submissions that an LNG plant will generate unpleasantodours. The current plant design incorporates an acid gas incinerator, which will combust all hydrogensulphide (H2S) removed by the amine unit, which would have been a primary source of odoursassociated with the project. In addition, all domestic and sanitary wastes will be professionally handledand managed by a waste management contractor in accordance with the Waste Management andPollution Control Act and general requirements of the DIPE, PAWA and Department of Health andCommunity Services (DHCS). As such, no significant off-site odour impacts are anticipated fromoperation of the Darwin LNG project. The proponent has indicated that it will ensure a high standardof housekeeping practices throughout the life of the project to minimise potential sources of odours asappropriate.

4.6 Greenhouse Gas Emissions

4.6.1 Greenhouse Gas Offsets

The PER predicts that the LNG facility will produce 18,000 tonnes/day of CO2 ; however, in a globalcontext, these emissions will be offset by reduced emissions of CO2 from LNG customers: per unitenergy produced, burning LNG produces less CO2 than fossil fuels and no SO2 or particulates, whichare of health concerns.

The PER guidelines required the proponent to provide information on a range of offsets including off-site energy efficiency measures. The PER and Offsets study did not consider potential options otherthan vegetation sinks and geological sequestration (i.e. re-injection of CO2 into the offshore gasreservoir before natural gas is piped to Darwin).

The proponent should note that future carbon prices are likely to be higher than current prices. Carbonis currently inexpensive as a result of uncertainty associated with future mandatory emission limits.With increased certainty, demand for emission ‘offsets’ is likely to rise more than supply. It shouldalso be noted that deforestation abatement is not an option under the Kyoto Protocol; however, it hasthe potential to be a domestic trading option.

The Offset Study recommendation to use oil mallee carbon offsets in preference to pine and eucalyptplantations is sound; however, the relative attraction of these options may change in time, asuncertainties regarding Australia’s ratification position and future carbon accounting modalities areresolved.

The proponent has indicated that, during the design and construction phases, it will continue toevaluate offset options as part of its ongoing management commitment and agrees these options need


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to not just include vegetation-related offsets but also other options that result in a reduction ofgreenhouse gases.

In its Response to Submissions, the proponent indicated that, as part of its identification andevaluation of options, it will include consideration of reforestation projects in East Timor and offsetswithin the Northern Territory. For the latter, the proponent will work with the Greenhouse Unit of theOffice of Environment and Heritage.

Recommendation 4

The proponent’s Environmental Management Program shall include a section specificallyaddressing commitments and strategies aimed at reducing greenhouse gas emissions. This shallinclude (for example) provisions for regular greenhouse gas audits, a process for continuousreview of new technologies to identify opportunities to reduce emissions, and benchmarkingagainst other LNG facilities with a view to achieving international best practice in terms of CO2emissions per unit of production. Opportunities for offsetting greenhouse gas emissions,including support for relevant research, shall also be addressed.

In developing its greenhouse gas strategy, the proponent shall consult with the Greenhouse Unitof the NT Office of Environment and Heritage, and the strategy shall be provided toEnvironment Australia.


4.7 Flaring (Heat Emissions)

Several submissions indicated that the PER did not provide adequate background information onflaring. The following description provides a more complete summary of key issues.

Flaring occurs at the LNG plant either as a result of the need to safely dispose of gases that cannot berecovered within the plant process (as a fuel source) or as a means to safely route gas from the facility.The processes that generate gas that requires flaring include

� Plant upsets, which interrupt processing and generate gases;

� Commissioning and initial start-up processing; and

� During loading of LNG vessels, when LNG cannot be kept at low enough temperatures tomaintain its liquid state.

The facility will have three types of flares:

� Wet gas flare (for gas streams that may contain moisture);

� Dry gas flare (for gas streams that are too cold to combine with moist streams); and

� Marine flare (to combust vapours displaced from ships’ tanks during loading).

In the 10 MTPA proposal, the wet and dry gas flares will be combined as a “main process flare” on theground (to minimise visual and heat impacts). The marine flare will be elevated (13 m).

One of the main environmental impacts from flaring methane is that it generates a significant amountof CO2 although almost an order of magnitude less than that produced by the gas turbine generators(0.3 MTPA vs. 2.6 MTPA CO2.).


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The other key issue is the potential impact of the main process flares on air traffic using DarwinAirport. Information received to date indicates no impact to the approaches is expected; however, theproponent is in ongoing discussions with the Civil Aviation Safety Authority (CASA) and itsconsultants in identifying and quantifying any potential impacts to airspace by the facility and indeveloping appropriate measures for mitigation.

Recommendation 5

This Assessment Report acknowledges the negotiations between the proponent, the CivilAviation Safety Authority (CASA), Darwin Airport authorities and other relevant agencies toresolve outstanding concerns regarding potential impacts from flaring on aviation. If continuingstudies indicate a potential significant risk to aviation, further analysis of hazards and risks toaircraft from flaring shall be required prior to the proponent’s final decisions on the design andoperation of flares.


The proponent has indicated that after the plant is commissioned and operational, typical flaringdurations during a plant start-up are expected to be less then 4 hours. The frequency and duration ofthe flaring shown in the PER reflects the proponent’s best estimate of how often these events willoccur based on experience from the proponent’s Kenai LNG facility and also the Atlantic LNG facility(Trinidad) which also uses the same LNG liquefaction technology.

The ground flare is expected to operate less than 108 hours/year. The marine is expected to operateapproximately 200 hours per year per train or 400 hours per year for the full 10 MTPA facility.

4.8 Wastewater and Stormwater Management

4.8.1 Temporary Sanitation Facilities

The PER indicated that during the construction phase, portable toilets would be used to accommodatethe workforce; however, this approach may not be sufficient for management of sanitary waste if themaximal predicted workforce of 1600 is realised.

In recognition of this potential inadequacy, the proponent, through its primary contractor, hasundertaken to establish procedures and plans for handling waste products generated on theconstruction site. These procedures will be developed to manage waste products in accordance withthe regulations of the DHCS. The proponent indicates that sanitary waste will be handled through acontract established with a removal and disposal company. The toilet facilities will comply with allrequirements of local health authorities and will likely consist of localised multi-station toiletbuildings. These will be dispersed where necessary throughout the construction site. The sanitarywaste from these toilet buildings will likely be collected in holding tanks. The sanitary waste from theholding tanks will be frequently collected and taken off site for disposal. A possible scenario is that theremoval and disposal Company will contract with the local sewage treatment works for disposal of thesanitary waste.

4.8.2 Hydrotest Water

To verify the integrity of pipelines and storage tanks, the proponent will conduct a “hydrotest” of thesestructures, i.e. fill storage tanks and transfer pipelines with water to test their strength. The proponentwill use freshwater or seawater with a range of chemical additives if necessary (to protect thesestructures from any potential impact from the hydrotest water).


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Use of freshwater

To minimise demand for freshwater, the proponent has considered the use of seawater to hydrotest theLNG storage tanks and believes that this may be a viable option. It is concerned about the impact ofthe higher corrosion rates that would result from the use of seawater, and the proponent’s ability toensure a timely and adequate cleaning of the interior of the tanks with freshwater after completion ofthe hydrotest. As a result of these concerns, the proponent currently prefers the use of freshwater forthe hydrotest of the tanks/pipelines. The use of seawater for the hydrotest of the tanks/pipelines will,however, be considered further and will be pursued if the proponent concludes that it is a safe andviable option.

Potentially toxic additives

The proponent is not yet certain that any potentially-toxic additives will be added to the hydrotestwater; however, if additives are required, based on current practice, Nalco EC1157A would probablybe selected. A product bulletin for Nalco EC1157A describes it as a “proprietary blend of watersoluble components including a non-aldehyde, low toxicity biocide, a bisulphitic based oxygenscavenger, and a phosphorous based corrosion inhibitor”. Features and benefits include that the “lowtoxicity of this material allows easy disposal of hydrotest fluid into the sea or effluent waters withoutfurther treatment”.

If toxic additives are to be used and pose a potential risk to marine biota, a Waste Discharge Licencewill be required. The Licence will require the proponent (in consultation with OEH) to assess thepotential toxicity of the hydrotest water and to monitor the receiving water to ensure dispersion anddilution reduce the risk to an acceptable level. Compliance with these guidelines should ensureprotection of the marine ecosystem and nearby aquaculturists; however, as an added safeguard, theproponent will provide adequate notice to aquaculturists before hydrotest water is released to allowthese facilities time to implement any desired safety measures.

Recommendation 6

If chemical additives used in hydrotest water pose a risk of toxicity to marine life in theHarbour, the proponent will require a Waste Discharge Licence. The Licence will require theproponent to analyse the hydrotest formulation to be used (to assess the potential toxicity tomarine biota) and to monitor the receiving water to ensure adequate dilution and dispersion toreduce toxicity to an acceptable level. Further, if there is a credible risk of toxicity in thedischarge, the proponent will provide adequate notice to nearby aquaculturists to allow themtime to implement desired precautionary measures. (This will comprise an additional safeguardto protect stock at these facilities.)


4.8.3 Irrigation with Treated Wastewater and Stormwater

Regarding wastewater management, the PER indicates that a closed-circuit re-use system will beimplemented (other than for contingent events such as saturation of the site from high intensity rainfallor plant breakdown) and process-contaminated stormwater will be included in this circuit.

The CPI oil/water separator will receive potentially contaminated stormwater from the process areasonly. The most probable contaminants will be a small quantity of oil and suspended solids. Design ofthe treatment system includes a secondary oil removal system and a final holding tank. Dischargefrom the holding tank to irrigation system will be monitored to ensure that the water quality issatisfactory for the purpose of irrigation.


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Given the substantial volumes of wastewater involved (288 m3/d), management strategies will have toconsider evaporation, transpiration, and perhaps infiltration within the disturbed area footprint.

The proposed facility includes effluent treatment (for subsequent irrigation on-site) for both processwastewater streams and potentially contaminated stormwater. In addition, a separate treatmentpackage is proposed for treating sanitary wastes. The PER does not identify the anticipated effluentcriteria that will apply to the process wastewater and potentially contaminated wastewater. The levelof treatment prior to irrigation (other than the removal of oil, grease and suspended solids) is not statedin the PER.

Recommendation 7

Treatment and disposal (by irrigation) of wastewater will need to comply with the Guidelines forSewerage Systems – Use of Reclaimed Water (ANZECC/ARMCANZ 2000) and Site Specific TypeApproval by the NT Department of Health and Community Services (DHCS). This will requirethe proponent to

� Conduct a detailed assessment of areas proposed for treatment and disposal using the DHCSSite Report template;

� Evaluate the site constraints in order to choose the most suitable system for treatment anddisposal of wastewater; and

� Submit the report to DHCS supporting an application for the Site Specific Type Approval.

Treatment and disposal systems must comply with the requirements of the DHCS Code ofPractice for Small On-site Sewage and Sullage Treatment Systems and the Disposal and Reuse ofSewage Effluent.


Detailed design of the proposed wastewater disposal system is not yet available. Once the amount ofgrassed and landscaped areas available for irrigation is determined for the plant site, the proponent willliaise with the DIPE, DHCS and other relevant NT Government agencies to design the mostenvironmentally-appropriate system for the site.

In its Response to Submissions, the proponent has undertaken to evaluate (during the detailed designphase) the feasibility and benefit of using local hardwoods for landscaping and soaking up irrigationwater.

To avoid impacts on the ecological integrity of surrounding dry rainforest, treated effluent will not beused to irrigate this vegetation.

The proponent has indicated that it will obtain the approvals and licences specified above and complywith their conditions.

4.8.4 Discharge (to Darwin Harbour) of Treated Wastewater and Stormwater

The proponent has indicated that uncontaminated stormwater will be segregated from potentiallycontaminated streams and disposed of by direct discharge to adjacent waters. Any stormwatercollected within the process area (which will be fully contained with bunds) will be routed to a drainsump and any potential oil derivatives skimmed from the collected water prior to discharge. As aresult, all best available measures will be employed to ensure that there will be no impact on DarwinHarbour water quality from stormwater exiting the site.


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Heavy wet season flows are likely to overwhelm the stormwater treatment system at Wickham Point,resulting in discharge of only partially treated stormwater to the Harbour. Once the design of theoverall wastewater treatment system is completed, the proponent will confirm with DIPE theconditions under which direct discharge to the Harbour may be required. If potential waste loads areof such magnitude that discharge may comprise a risk to nearby aquaculture facilities, the proponentwill model the likely trajectory of the wastewater discharge. If results of this modelling indicate thatparticular facilities would be at risk of taking up contaminated water, then the proponent will liaisewith these facilities to develop contingency plants to protect their operations

The proponent acknowledges that a Waste Discharge Licence will be required for discharge of treatedeffluent to Darwin Harbour.

In its Response to Submissions, the proponent addressed the potential cumulative impacts of directdischarge of effluent and provided further details on treatment processes and segregated waste streams(produced water, wastewater from plant operations and treated sewage).

The predicted annual loads of contaminants from the plant were compared to the current (estimated)annual loads from stormwater into Darwin Harbour (DLPE 2000).

In brief, the comparisons indicated that the contribution of potential contaminants to Darwin Harbourfrom the facility would be small:

� Total Nitrogen – Annual load from plant = 86.7 kg/yr vs. 589,000 for the total catchment,144,000 kg/yr from PAWA sewage plants;

� Total Suspended Solids – Annual load from the plant = 4.4 tonnes/yr vs. 25,326 tonnes/yrfrom catchment inflows; and

� Oil – No data available on annual loads. Total load from the plant, however, will beapproximately 6.6 tonnes (approximately 8 – 9 m3); therefore, the load will be very small.Potential impacts will be minimised because, when released in low concentrations intoreceiving waters, this oil should rapidly bio-degrade, weather and therefore not accumulate.Further, where/when possible these effluents will be discharged on-site for irrigation, tominimise discharges to the Harbour.

4.8.5 Radioactive Waste

The PER does not indicate whether the production of LNG is associated with radiological issues. In itsResponse to Submissions, the proponent reported that analysis of the LNG feed gas indicatedradioactive material of 29 +/- 22 Bq/m3. The proponent considers these levels to be very low and doesnot anticipate any significant issues with respect to contaminated waste streams (owing to plating-outof mercury onto process piping). There will be no produced water at the LNG plant in that the productfeed gas stream will be dry gas. The formation of naturally-occurring radioactive materials (NORMs)will be largely related to radioactive films of decay products of radon gas (210Pb and 210Po) on internalprocess piping. (The radon gas is generated by decay of radium in the formation sands in the offshoreproduction process and a fraction of radon is mixed with the gas stream.)

Should there be any disposal requirements the proponent will comply with all applicable NTregulations and the "Guideline for Application for Approval to Dispose of Petroleum RelatedNORM - EG 506" (DBIRD 2002).


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4.9 Solid and Semi-liquid Waste Disposal

The proponent will be actively working to identify waste minimisation and recycling opportunities toreduce solid and semi-liquid waste streams where possible. An Operational Waste Management Plan,prepared as part of the Environmental Management Program (EMP), will detail the proponent’sapproach to managing these wastes. The EMP will be subject to approval by the NT Government.

4.9.1 Adequacy of Shoal Bay Waste Disposal Site (SBWDS)

The proponent indicates that the volumes of waste generated from the proposed 10 MTPA plant willbe of a suitable quantity for disposal to Shoal Bay Waste Disposal Site (SBWDS). A third cell hasrecently been constructed at the SBWDS to accommodate Darwin and Palmerston municipal waste(combined population in excess of 115,000 people). The PER (Table 4.1) indicates that the proposed10 MTPA facility will generate approximately 157.5 tonnes of municipal rubbish (trash), ceramic ballsand molecular sieve waste per annum. The Darwin City Council publication ‘Waste ManagementStrategy: Towards 2000’ (1995) estimates that Darwin residents generate approximately 1 tonnemunicipal waste per annum. The 10 MTPA plant will therefore generate the equivalent waste fromapproximately 158 people, which is anticipated to be easily accommodated at the SBWDS, oralternatively the Humpty Doo Landfill.

The SBWDS is not suitable for disposal of the following wastes (refer Table 4.1):� Waste Lubricating oils;� Spent Oils;� Biological Sludge;� Inorganic Sludge;� Oily sludge; and� Spent Solvents.

These wastes will be disposed of by commercial waste management contractors as appropriate (e.g.oils to the Mataranka Lime Kiln). The PER indicates that the proponent will review waste-trackingdocumentation from the contractor to ensure these wastes are disposed in a manner approved by OEH.

4.9.2 Construction Wastes

The PER provides annual operational waste generation estimates (in Table 4.1 ‘Estimated LNGFacility Solid Waste Quantities’). The types of construction wastes anticipated are detailed underTable 2.1 and in Section 4.3.5.1 of the PER; however, the proponent did not indicate likely quantities(citing the difficulty in predicting these).

In its preliminary EMP, the proponent indicated that, where practical, it will use cleared terrestrialvegetation and/or mangroves for rehabilitation. Excess amounts may be chipped and used as mulch.Cleared vegetation should not be stockpiled on-site as this could create breeding habitat for bitinginsects. Burning of cleared vegetation containing noxious weeds is under consideration as a bestmanagement practice to prevent the spread of noxious weeds and/or plant pathogens.

In order to avoid land subsidence, geo-technical advice should be sought if vegetation will be left inplace and covered with fill.

The proponent does not anticipate excess clean fill from land operations. Cut and fill requirements areexpected to be balanced. Transportation of suitable dredged materials to East Arm Port remains underconsideration.


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There is no recycling facility planned on-site for construction wastes. A temporary area will beestablished for the stockpiling of scrap metal (which will be collected for off-site recycling and/ordisposal). Construction wastes will not be disposed of on-site.

A full description of the proponent’s plans for management of construction wastes will be included inthe Construction EMP.

4.9.3 Biological Sludge

The PER indicates that approximately five tonnes of biological sludge will be generated annually. Thesludge from the sewage treatment plant will be de-watered by waste contractors, with the residualsolids tested (as required) and disposed to landfill. Five tonnes of biological sludge per year is theequivalent annual waste generation of approximately five people, and the SBWDS is anticipated tohave adequate capacity to accommodate this volume.

4.9.4 Disposal of Cellulose/Molecular Sieves and Ceramic Balls

Cellulose/molecular sieves are used in the dehydration unit to absorb moisture out of the gas stream.Ceramic balls are used to support the molecular sieve and to break-up the gas flow so a better gasdistribution through the sieve can be achieved. (The balls are approximately 1-3 cm in diameter.)These wastes have been classified as non-hazardous and suitable for disposal in landfills, based on theproponent’s experience in disposal of these wastes in similar service. Typical disposal techniques aredescribed in the PER.

4.9.5 Spent Amine

Amine treatment will be used to strip acid gas from the gas stream prior to entering the liquefactionprocess.

The proponent does not intend to dispose of spent amine but instead recover amine for re-use withinthe process. The plant design will incorporate various piping systems and equipment to facilitate thecollection and re-use of amine. Reaction of amine with other constituents to form chemicals ofconcern is also not expected based on the proponent’s past experience; however, the proponent willaddress options for disposal of spent amine in the Operational Waste Management Plan.

4.9.6 Carbon Beds (containing waste mercury)

When the facility is to be decommissioned, the proponent acknowledges that carbon beds containing apredicted 132 kg of mercury (3.3 kg/yr for 20 yrs x two beds) may not be suitable for disposal at anylandfill site. The proponent indicates that other options for treatment and disposal of this waste will beaddressed in the Operational Waste Management Plan.

4.9.7 Waste Oil

The PER indicates that waste oils will be recycled or disposed of through a commercial contractor,e.g. for delivery (as fuel) to the Mataranka Lime Kilns. Because of volatile market-driven factors,however, at times there may be no ability to recycle or re-use this oil locally, and alternativearrangements will have to be made (e.g. stockpiling on-site until suitable disposal can be arranged).The proponent should liaise with OEH to develop acceptable options for management of waste oil.


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Recommendation 8

The proponent will consult with the Office of Environment and Heritage to develop preferredand contingency options for management and disposal of waste oil and will include these in itsEnvironmental Management Program.


4.10 Impact of Rock Groynes

Introduction of rock groynes and other structures has the potential to cause erosion on the“downstream” side and sedimentation on the “upstream” side. These disturbances to sea-bedsediments could, at least until a new equilibrium is reached, also increase the level of suspended solidsin Harbour and thus decrease water quality.

Hydrodyamic modelling for the previous environmental impact assessment (for the 3 MTPA plant)indicated that tidal velocities near the construction dock were low (< 0.05 m/s) and changes frominstallation of the dock were undetectable. Tidal velocities in the lee of the product-loading jetty werepredicted to be reduced, particularly during ebb tides, potentially resulting in deposition of sedimentson both sides of the groyne, as has been observed for the East Arm Port groynes.

Both groynes are predicted to result in increased stability and sedimentation of the adjacent shoreline,without significant erosion. Current speeds will increase slightly at the seaward end of the loadingjetty groyne, but, as this will be located on existing rock pavement, no erosion is anticipated.

4.11 Dredging and Disposal of Spoil

The proposed construction dock will require dredging, and some dredging may also be necessary atthe head of the product-loading jetty. Introduction of rock groynes and other structures may affect thehydrodynamics of the harbour (e.g. cause erosion and/sedimentation in adjacent areas). The dredgingitself will have impacts on water quality, and a prolonged significant decrease in water quality couldpotentially impact attached or slow-moving biota or aquaculture facilities (which depend on waterquality of an acceptably-high standard).

In its Response to Submissions, the proponent indicated that it will further characterise seabedsediments to refine predictions on the likely extent and duration of dredge plumes, as part of itsDredge and Spoil Disposal Management Plan (part of the EMP).

The PER indicated that the proponent may apply for a permit to side-cast dredged material (i.e.discharge dredged spoil into the Harbour without prior settlement and clearing of water in retentionponds before discharge of decant water back to the Harbour). This would be allowed only if the natureof the material, timing of dredging and discharge, and other management approaches were determinedby OEH to pose minimal risk to the biota of Darwin Harbour and industries dependent on high waterquality. The proponent would need to obtain a Waste Discharge Licence prior to dredging and complywith all requirements attached to the Licence.

The PER indicates other options for management of dredge spoil, including use (as fill) on-site or atEast Arm Port (if material is of acceptable quality), or discharge of decant water after dredge spoil hasbeen settled in retention ponds. The proponent will apply a “decision-matrix” in its consideration ofuse/disposal options, in consultation with DIPE and the Darwin Port Corporation (DPC) indevelopment of the Dredge and Spoil Disposal Management Plan indicated above and prior to anydredging activities off Wickham Point. Discharge of decant water from ponds would also require theproponent to obtain a Waste Discharge Licence.


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To avoid the unacceptable impacts that might be associated with production of plumes fromsimultaneous dredging at both Wickham Point and East Arm Port, the proponent and the DPC willneed to work together to coordinate their dredging schedules and Reactive Monitoring Programs.

One submission from the review of the PER suggested that the Darwin Aquaculture Centre (DAC)may be at risk from sediment plumes generated by dredging during the construction and operationalphases of this project, as the centre is located close to Wickham Point. At present, wet season impactson sediment transport throughout the Harbour already result in a few days each year when waterquality is reduced to a level unacceptable for aquaculture. If the period of unacceptable water qualitywere to be extended for longer periods by dredging, this might seriously impact the operation of theDAC.

The PER suggests that water quality impacts will not be detectable more than 700 m from the site ofdredging. The very fine nature of some of the sediments and high current speeds in Darwin Harbour,however, can quickly transport sediments over great distances, and even minute changes in waterquality can affect the DAC’s production and experiments. Dredging for the construction dock poses asmaller risk of impact on the Centre than dredging for the product-loading jetty, as the former is inEast Arm and the latter in Middle Arm and closer to the DAC. The project will require dredging at theconstruction dock; however, dredging may not be needed at the jetty.

The proponent consulted with the DAC during preparation of the PER, and the proponent indicated itsintention to continue a close liaison role with the Centre prior to dredging activities. Previousmodelling has predicted that the extent of turbid plumes would be unlikely to impact the activities ofthe DAC or the nearby Channel Island coral community. The proponent will, however, as part of theDredge and Spoil Disposal Management Plan, outline management measures to ensure that dredgingwill cause no adverse impacts, including the establishment of a reactive turbidity monitoring programsimilar to that endorsed by DIPE for the East Arm Port development.

The Plan will be developed in consultation with Fisheries Division (DBIRD), DPIE and DAC andapproved by these agencies before dredging commences.

Recommendation 9

The proponent’s Environmental Management Plan shall contain a Dredge and Spoil DisposalManagement Plan that evaluates options for dredging, excavation and spoil disposal andaddresses potential environmental impacts. This Plan shall include proposed measures toensure protection of the Channel Island coral assemblages. The Plan shall also include a“Reactive Monitoring Program” that implements baseline studies (to set environmental triggersfor concern), turbidity plume monitoring, a reactive coral monitoring program (if required),and contingency measures to be implemented if environmental triggers are exceeded or ifmonitoring detects potentially unacceptable environmental impacts.

Development of the Dredge and Spoil Disposal Management Plan shall be done in consultationwith relevant NT Government agencies and shall be submitted to the NT Government forapproval prior to commencement of dredging.


4.12 Risks from Shipping

The proponent considers the main threat of significant, irreversible environmental damage associatedwith the project would be from a shipping incident in the Harbour, which could result in a substantialoil spill with consequential mortality of mangroves and associated biota. The risk, however, will bemitigated by controls on navigation, the double-hulled design of vessels, and oil spill contingencyplans to be prepared by the proponent and included in the EMP.


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Shipping movements will be coordinated through the Darwin Port Corporation. Vessels will beescorted by tugs in the vicinity of the loading jetty and will be under the control of a pilot withinHarbour waters, to ensure compliance with all procedures for safe navigation, including maintenanceof required separation distances from other vessels.

A 500 m “moving exclusion zone” around each LNG ship as it proceeds through the Harbour to theproduct-loading jetty is proposed, to minimise safety risks. The proponent has also undertaken toliaise with the Royal Australian Navy to eliminate traffic conflicts and minimise risks from possibleinteractions with naval traffic.

The PER also indicated that an emergency plan for LNG carriers will be based on an understanding ofthe types of accident that could occur and their possible consequences, together with an effectivesystem of communication. The proponent indicated that written procedures will be developed inliaison with the Darwin Port Corporation.

Recommendation 10

An emergency management plan addressing LNG carrier operations at sea, in Darwin Harbourand at the loading jetty shall be developed in consultation with relevant authorities such as theDarwin Port Corporation and the Australian Maritime Safety Authority. The plan shall include

� measures to ensure compliance with national and international safety regimes;

� reporting procedures and organisational responsibilities in the event of incidents;

� contingency measures to minimise risks to human safety and the environment;

� specification of adequate resources to be held on ship and at berth to deal with crediblecontingencies; and

� a communication strategy to ensure effective and efficient liaison among shore-based andship-based emergency response teams.


The Darwin Port Corporation (DPC) has jurisdiction for spills in Darwin Harbour and has an Oil SpillContingency Plan (OSC) as part of the National Plan to Combat Pollution of the Sea by Oil(NATPLAN). Oil spills could occur during the construction or operational phases of the project, fromincidents involving dredges or vessels using the construction dock or product-loading jetty. Theproponent has indicated that it will prepare OSCP’s for each of these phases, in consultation with theDarwin Port Corporation and other relevant authorities, and integrate these into the existing DarwinHarbour OSCP.

Recommendation 11

Oil spill contingency plans for the construction dock and product-loading jetty shall be preparedby the proponent, within the overall context of the Darwin Port Corporation’s Oil SpillContingency Plan. The site-specific plan shall include

� an assessment of potential risks of spills of credible volumes;

� potential oil spill trajectories;

� maps of priority areas for protection (including aquaculture facilities);

� details for deployment of equipment to protect priority areas,

� demonstrated integration with the Darwin Port Corporation Plan;


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� inventory of equipment for control and clean-up (including materials held at the jetty and/orconstruction dock for immediate clean-up of minor spills);

� strategies, actions and responsibilities for any clean-up; and

� a training and exercise strategy that includes relevant NT Government response personnel.


4.12.1 Navigational Hazard from Charles Point Patches

The PER indicated that there are no tidal constraints for vessels up to 11.5 m draft; however, theproponent should note that access to Darwin Harbour (for a static draft of 11.5 m plus under-keelclearance) will be restricted by the present 12.2 m clearance depth at low water at Charles PointPatches. This matter is recognised by the Darwin Port Corporation (DPC) and is the subject ofseparate capital works programming and environmental impact assessment process. The proponenthas indicated that it will continue to liaise with the DPC to resolve this issue.

4.12.2 Berthing and Departure Procedures

Simulation of vessel movements was required to identify any restrictions to be applied to vesselmovements to ensure safe navigation for berthing and departing the jetty at the LNG plant.

In February 1997 the proponent undertook a Ship Manoeuvring Study using the Ship HandlingSimulator at the Australian Maritime College. This study was done to gain an understanding of the tugrequirements and operational constraints and other aspects of ship handling and navigation in regard tothis project. The area adopted for the study was bounded in the north by the offshore pilot boardingarea northeast of the Charles Point Patches Buoy (No.5) in a depth of 18-20 metres and to the south bythe proposed berth site in Middle Arm, west of Peak Hill.

As a result of this study, issues such as berth location, berth alignment, tug requirements, berthavailability, and dredging requirements were identified and assessed. The proponent has indicated thatit will review the results of this study with the Darwin Port Corporation, including any changes theproject has incurred since that time or as a result of this study, and determine what additionalsimulation efforts are required to finalise the berthing and departures procedures for the LNG vesselsfor all states of the tide and weather conditions.

In response to one submission, the proponent reported that neither the Darwin Port Corporation nor theAustralian Navy raised concern about the potential hazard posed by the Darwin Naval Basebreakwater to navigation of LNG vessels. The proponent, however, indicated that continuing hazardand risk assessment studies that consider marine transportation issues will include grounding andfixed-object collision concerns.

4.13 Hazards and Risks (public and environmental)

4.13.1 Hazard and Risk Analysis

In 1998, the proponent was given approval to construct a 3 MTPA LNG plant at Wickham Point, onthe basis that a Hazard and Operational (HAZOP) Study and Quantitative Risk Assessment (QRA)would be done for the proposal, and results presented in the Environmental Management Program.

During the detailed design stage for the 10 MTPA LNG project, the proponent has undertaken tocomplete the following and include results in the EMP:


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� A final HAZOP Study, to identify all potential scenarios arising from the failure of valves/controlsor other plant upsets;

� A final QRA, to identify, evaluate and manage all potential risks associated with the project; and

� A detailed Safety Report for the LNG plant, in accordance with relevant Worksafe AustraliaStandards and prepared on the basis of the HAZOP and QRA studies indicated above.

The purpose of the Hazard and Risk Assessment presented in Appendix G of the PER is todemonstrate that the 1 km buffer around the proposed site and 7 km separation from the Darwin CBDis sufficient to ensure that in the event of catastrophic failure of the plant there will be minimal risk ofloss of property and human life at Darwin. The Proponent acknowledges however that Appendix G islong and technical in nature and may be difficult for laypersons to understand. The concern regardingthe downwind dispersal of an “asphyxiating and potentially flammable” cloud of LNG gas isaddressed in the Preliminary Siting Study by Quest in Table 4-4 and Figure 4-5a of the PER.

Table 4-4 – “The maximum downwind distance to the hazard endpoint” – indicates the maximumdistance that an asphyxiating and potentially flammable hazard originating from the liquefaction plantcould occur in any direction under worst case conditions which are at low wind speeds. Higher windspeeds disperse the gas more quickly and result in a smaller downwind hazard distance. As indicatedin Table 4-4, the maximum distance downwind that a hazard may exist is 575 m for a release from theethylene refrigerant surge drum. Figure 4-5a presents this hazard diagrammatically and shows thelocation of the hazard area under a light (2m/sec) south east wind and stable atmospheric conditions(worst case for dispersal of gas).

Similar assessments are available for the LNG storage tanks (Refer Table 4-2 and Figure 4-1: note thatthe hazard is maintained within the overall LNG spill impoundment area) and the jetty head (referFigure 4-2).

Table 4-4 also indicates the maximum downwind distance that radiant heat is a hazard from theliquefaction plant. Please note that for this hazard, higher wind speeds (9 m/sec) are considered worstcase because strong wind can blow the heat plume a small distance downwind.

Figures presenting modelling results in the Quest report show that all hazards (both radiant heat andflammable dispersion) occur within the plant site boundary or within approximately 400 m of the jettyhead (hence the proposed 500 m safety exclusion zone).

LNG is stored at atmospheric pressure and would not explode if vessels storing the material wereruptured. In such an event, the LNG, being very cold and dense, would flow downhill into acontainment pond. The LNG would only ignite if a naked flame is present, and even then it wouldburn rather than explode.

The proponent indicates that results from the Qualitative Risk Assessment presented in the PERindicate that the potential hazards to the public and on-site personnel, arising from operation of theLNG plant, would be maintained at an acceptably low level at the plant boundary.

The Quantitative Risk Assessment is likely to indicate an even smaller risk, because the preliminaryanalyses (i.e. Qualitative Hazard and Risk Assessment, in Appendix G of the PER) used much moreconservative assumptions than those required once final plant design details are known and final riskand hazard analyses are completed.

Approval of the EMP will include acceptance of the outcomes of these studies, i.e. that the risks topeople, the environment and adjacent facilities (e.g. power plant and aquaculture centre on or nearChannel Island) are considered acceptably low.


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If an arterial road from Wickham Point is constructed and development occurs along that road, theproponent has agreed to liaise with relevant authorities and key stakeholders on Wickham PointPeninsula to fully investigate the potentially greater risk to the public.

4.13.2 Cyclones

The Hazard and Risk Analysis above included the potential for damage by cyclones, andinfrastructure at the plant has been designed to minimise the risk of significant damage (e.g. LNGstorage tanks have a concrete outer shell). The proponent has indicated its proven experience in thedesign of facilities vulnerable to tropical storms (i.e. the Atlantic plant at Trinidad), and the design forthe plant will be in accordance with the requirements of AS 1170.1, SAA Code: Dead and Live Loadsand Load Combinations (Australian Standards Australia 1989), which would specify minimumstandards for resistance in high winds.

Further details relating to the proponent’s contingency planning for cyclones are included in Section 5of this Assessment Report.

4.13.3 Lightning Strikes and Power Failures

In its Response to Submissions, the proponent indicated that the entire plant is protected with anearthing grid and lightning rods installed at high points within the plant. In addition, all of theequipment, piping, etc. within the plant is grounded to the earthing grid. This will protect the plantfrom lightning strikes by channelling the lightning to ground and preventing damage to the plant. Theproponent indicates that this is similar in principle to the system that PAWA uses to protect theelectrical distribution line from Channel Island to Darwin.

In the rare event that lightning were to strike part of the control system within the plant, it woulddisable that individual control loop; however, the plant control system is designed to allow the plant tosafely operate with individual control loop failures.

In the event of a power failure to the plant for any reason, the plant is designed to automaticallyshutdown (fail safe). For this purpose, the plant incorporates various back-up systems, such as batteryback-up power for critical systems and valves that fail to a safe condition.

4.13.4 Transport of Hazardous Materials

An assessment of hazardous goods transported to, and hazardous wastes transported from, the plant iswarranted. The amount of hazardous petroleum waste produced by the facility could be significant (ina regional or local context), and the transport corridor for the facility will extend through sensitivenatural environments and populated areas (such as Palmerston).

The proponent has undertaken to do an assessment of hazardous wastes transported to and from theplant. Contingency plans to be prepared for the EMP will incorporate a plan to deal with anyaccidental spillage of hazardous goods during transport.

4.13.5 Safety Report

In the PER, the proponent indicates that, during the detailed engineering phase of the project, acomprehensive Safety Report will be prepared for the LNG plant in accordance with the requirementsof the National Code of Practice for Major Hazard Facilities. The proponent will consult with the NTGovernment during development of the Safety Report and emergency response manuals to ensure thesafe design and operation of the LNG plant.


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4.13.6 Environmental Performance of Kenai LNG Plant (Alaska)

Subsequent to provision of the Response to Submissions, the proponent provided a summary of theenvironmental performance of its LNG Plant in Alaska, in particular leaks/spillage of oils andhazardous substances. (This information was requested by OEH to supplement summary tables ofincidents specifically involving LNG, in Appendix G of the PER.) From January 1995 to May 2001,there were fourteen spills/leaks of diesel, turbine oil, hydraulic fluid, lube oils, glycol, steamcondensate and sulfuric acid. More than half of these were under 20 litres and resulted primarily fromhose leaks or during transfers. The most significant spills were

� 227 litres of diesel, from a leak in a bunker loading line (during re-commissioning);� 76 litres of turbine oil, during a propane compressor oil transfer;� 95 litres of diesel, during de-inventory of a loading line; and� 7 litres of sulfuric acid, from a leaking pipe at the cooling tower.

The proponent indicated that equipment re-design will prevent leaks of turbine oil at the Darwinfacility; glycol will be removed from the gas stream offshore; and because there is no cooling tower atthe Darwin facility, no sulfuric acid is needed to clean the tower.

4.14 Ecological Impacts

4.14.1 Dry Rainforest ( = monsoon vine thicket)

Clearing of vegetation

Fourteen plant communities have been identified at Wickham Point. No rare, endangered or threatenedplant species were recorded for the site; however, the dry rainforest is recognised to be of conservationinterest. The Litchfield Area Plan 1992 applies to the site and indicates that

� Except with the consent of the [Development Consent] Authority, the removal of naturalvegetation from an area within an allotment exceeding approximately 50% of the area of theallotment is prohibited; and

� Where removal of native vegetation is proposed for an area exceeding 50% of an allotment, thevegetation is removed in accordance with environmental guidelines.

The PER indicates that the total land area for the LNG site is 88.3 ha, which is approximately 48% ofthe current total site; therefore, consent for vegetation clearance is not required.

Clearing of vegetation should be staged to meet the minimal requirements of constructing andoperating the facility and to avoid clearing land that might never be used.


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Recommendation 12

The proponent’s Environmental Management Program shall include specific measures tominimise loss and disturbance to remaining mangrove and dry rainforest habitat at WickhamPoint. This shall include measures to avoid unnecessary clearing and disturbance duringconstruction, measures to monitor and control weed and feral animal incursions, and measuresto minimise fire risks.

[ = Recommendation 11 in Assessment Report 24]

Selection of offset area(s)

The acquisition of an area of dry rainforest is proposed in the PER to offset removal of dry rainforestwithin the project area; however, the size of the area to be acquired and the long term managementarrangements for this acquired land are not discussed in the PER.

The proponent has maintained an ongoing dialogue with DIPE throughout the preparation of the PERto identify an acceptable dry rainforest mitigation strategy. It will continue to liaise with DIPE andjointly develop a program to offset the area of dry rainforest that has been removed for thedevelopment of the LNG facility.

4.14.2 Mangroves and Salt-flat Habitat

The proposed expansion will require removal of 88.3 ha of native vegetation, of which 11.9 hacomprise mangrove community (of a Harbour total of 20,400 ha) and 1.8 ha comprise salt-flat habitat.

The preliminary EMP (Dames and Moore 1998b) includes the proponent’s commitment to mangrovemonitoring in relation to productivity of mangroves adjacent to the development site. Mangrovemonitoring procedures for Darwin Harbour have been further developed by DIPE and the NorthernTerritory University (NTU) since preparation of the preliminary EMP.

In its Response to Submissions, the proponent states that it intends to review the proposed mangrovemonitoring procedures in consultation with the DIPE, to ensure current recommended methods areused. These updated procedures will be incorporated into the revised EMP.

4.14.3 Impacts on Terrestrial Fauna

Fauna corridors

The proposed site layout does not appear to provide any fauna corridors linking the northern tip ofWickham Point to the remainder of the peninsula.

The proponent does not intend to fence-off the landward approaches to the construction dock. It isanticipated that most animals will be able to traverse the landward end of the construction dock atnight during the construction period, and at any time thereafter. The proponent will mitigate the effectof the barrier presented by the construction groyne at the high tide level by constructing earth rampson either side of the groyne, if deemed necessary by DIPE.


May 200232

Birds

Regarding potential impact on federally listed migratory species such as the Melville Cicadabird andthe White-Bellied Sea Eagle, information from the Parks and Wildlife Division (of DIPE) suggeststhat local populations of these species are unlikely to be affected by the loss of habitat what will resultfrom the proposal. The Melville Cicadabird prefers dense mangrove habitat (of which only 11.9 hawill be cleared), and the Sea Eagle prefers high trees for roosting and nesting.

4.14.4 Impacts on Marine Biota

The proponent has undertaken to mitigate risks to the marine biota of Darwin Harbour by minimisingthe discharge of potential contaminants into the Harbour and by ensuring that discharges comply withrequirements attached to Waste Discharge Licences obtained by the proponent.

Details regarding management of wastewater, stormwater and dredge spoil have already beenprovided under other headings in this Section of the Assessment Report (Section 4).

4.14.5 Fire, Weeds and Feral Pests

The proponent has undertaken to produce and implement a comprehensive weed management planprior to construction of the facility. The proponent has indicated that it is fully aware of therequirements of the Weeds Management Act and will ensure that all activities are in full compliancewith the Act. The proponent has undertaken to liaise closely with the DIPE to minimise the spread andprevalence of weeds on Wickham Point.

4.14.6 Exotic Marine Pests (from discharge of ballast from ships)

Each LNG vessel coming to Darwin will be discharging up to 48,000 m3 of ballast water. DarwinHarbour has already experienced several outbreaks of exotic pests in recent times, although the mostserious of these probably resulted from organisms attached to the hulls of vessels rather than bydischarge of ballast. These outbreaks have been successfully treated. The Fisheries Division of theDepartment of Business, Industry and Resource Development (DBIRD) operates a program to monitorfor exotic marine pests.

Shipping activities under the proponent’s control will comply with the Australian regulations for themanagement of ballast water and general Australian Quarantine and Inspection Service(AQIS)guidelines, which will ensure that no ballast water exchange occurs within or near Darwin Harbour.Re-ballasting at sea, as recommended by the IMO & AQIS guidelines, currently provides the bestavailable measure to reduce the risk of transfer of harmful aquatic organisms.

In its Response to Submissions, the proponent acknowledged the requirement to liaise with DBIRDregarding the exotic marine pests monitoring program and mitigation of potential impacts fromshipping associated with the proposed project. The proponent indicated that it is aware of additionalR&D efforts currently underway to identify additional ballast water treatment technologies, such assterilisation by ozone, ultra-violet light, electric currents and heat treatment, or chemical treatmentmethods such adding biocides to ballast water to kill organisms. These technologies are, however, notyet proven and not currently accepted by the global R&D community.


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4.15 Noise

4.15.1 Construction Phase

Pile-driving

One submission raised the issue of potentially unacceptable levels of noise from pile-driving.

In its Response to Submissions, the proponent indicated that it is not certain that pile drivingoperations will be required to construct the load-out jetty. Recently completed geo-technicalinvestigations indicated that drilling and grouting the piles may be a preferable approach. In the eventthat pile driving is considered necessary, the proponent indicated that the potential noise impacts onthe residents of Darwin and Palmerston will be modelled. If findings indicate a significant potentialfor disturbance to residents, a Noise Management Plan for this temporary activity will be prepared (inconsultation with OEH) and implemented by the proponent.

Noise propagation over water

Another submission indicated that construction noise from the East Arm Port development could beheard at residential areas 6 km away (straight-line distance, over water). As the LNG plant is 7 kmaway from the Darwin CBD, the proponent was asked (in the NT Government submission) to verifyits prediction of no significant impact off-site from noise. In response, the proponent has re-stated itscommitment to undertake construction work during daylight hours, when background levels of noiseat these nearby populated areas will be high.

Blasting/detonations

In its Response to Submissions, the proponent indicated that recently completed geo-technicalinvestigations suggest that the rocky material on the site is readily rippable by standard earth-movingequipment; therefore, the use of explosives should not be required. In the unanticipated event thatexplosives are required, noise reduction measures, such as the use of weighted blankets, will beadopted.

4.15.2 Noise during Upset/Emergency Operating Conditions

The proponent indicated that during plant upsets/emergency operation, various areas within the plantmight experience higher noise levels for brief periods of time. The most significant increase would befrom compressor recirculation, which occurs during the majority of plant upsets. Estimated noise levelincrease from this source is expected to be up to 10 db in the A-weighted sound pressure level but theimpact at the plant boundary may be higher by only 2-5 dBA. As this attenuates outward it is expectedthat the noise levels off the plant site will stay below World Bank guidelines for day- and night-timenoise in residential areas. During this recycle situation alternate compressors may not be operatingthus overall impact will not be significant.

4.15.3 Requirements under the NT draft Waste Management and Pollution Control(Environmental Noise) Regulations

Although the PER refers to USEPA and World Bank guidelines in its prediction and assessment ofnoise, the more locally-relevant NT draft Waste Management and Pollution Control (EnvironmentalNoise) Regulations were not adequately considered. These regulations are likely to come into effectduring construction of the LNG facility.

The proponent indicated that it will contact the OEH to confirm the requirements of the draftRegulations. Based on the modelling undertaken to date (Appendix E of the PER), the LNG facility is


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predicted to generate no significant off-site noise impacts. The proponent has indicated that it willensure that noise during construction and operation of the plant will be managed to comply with theRegulations when they come into effect.

4.16 Work Health Issues

4.16.1 Biting Insects

The PER indicates that biting insects (mosquitoes and midges) are common at Wickham Point andpose a potential nuisance and health risk to staff.

Mosquitoes

The greatest potential for the creation of new mosquito breeding sites will arise with disturbances byconstruction activities in or near tidal areas. Given the increased size of the proposal, there is a greaterpotential for creation of new breeding areas during construction.

In its Response to Submissions, the proponent acknowledged that management of biting insects is anissue it needs to address in relation to the Wickham Point site. The proponent indicated itscommitment to minimising impacts that the plant construction could have on existing biting insectnumbers and to controlling the effects of biting insects on the health and well-being of personnel in thevicinity of the site.

The Preliminary EMP committed the proponent to complying with the NT Government’s guidelines,“Construction Practice near Tidal Areas in the Northern Territory – Guidelines to Prevent MosquitoBreeding (Whelan 1988). In completing the final EMP, the proponent will further refine its approach,which will form the basis of a Biting Insects Management Plan to be established in accordance withDepartment of Health and Community Services recommendations.

Biting midges

The biting midge species Culicoides ornatus is likely to be a severe pest in at least the eastern half ofthe “island” and possibly the whole of the island area. Significant sources of C.ornatus are likely tooriginate from the wide mangrove margins at the south-east end of the island.

The control of biting midges is not likely to be practical or effective under most circumstances.Strategies to mitigate the potential pest problem should therefore include avoiding known problemareas by siting any high-use personnel areas in the south west of the island. Any personnel facilitiesshould be constructed with the ability to be screened or sealed from biting midge entry. (Biting midgeswill penetrate standard insect screening.)

Personal protection of employees from biting midges will be employed and induction trainingimplemented to ensure that the problem is managed in accordance with recommendations by theDHCS. The proponent will detail its approach to these issues in the EMP.

4.16.2 Radiation

As indicated in Section 4.8.5 of this Assessment Report, the proponent indicated that the LNG feedgas contains only low levels of radioactive material (29 +/- 22 Bq/m3).

With regard to occupational risk, although considered to be low, the proponent has undertaken toaddress this issue by developing procedures for naturally occurring radioactive materials (NORMs),


May 200235

which will be implemented for protection of personnel during plant shutdown and maintenanceactivities.

Final equipment selection will occur during the detailed design phase of the plant. At that time anyequipment that is likely to contain radiation sources and/or irradiating apparatus will be identified. Theproponent indicated that operation of this equipment will comply with the provisions of the NTRadiation (Safety Control) Act.

4.17 Impacts on Visual Amenity

The PER summarises results from a visual impact assessment that compared the 3 MTPA plant to the10 MTPA facility, based on a number of vantage points on land and on the water and an aerial view.The results indicate that the visual impacts associated with both plants are comparable, with theexception of the larger capacity LNG storage tanks; however, these were not likely to significantlyimpinge on the landscape from Darwin Harbour.

The results indicate that some components, such as the main process flares, would have a muchsmaller impact because of their location on the ground rather than elevated (as was proposed for the3 MTPA plant).

The visual impacts would be greatest within 500 m of the facility, jetty, construction dock, etc.Beyond 500 m, the visual impact of the development would diminish. The PER considered thatsensitive locations would be well in excess of 500 m from Wickham Point.

In its Response to Submissions, the proponent indicated that the plant site was selected to minimisethe amount of earthworks and utilise the western ridge to shield it from view from Darwin. Peak Hill,the taller of the two primary ridgelines on the Wickham Point Peninsula, will remain largely intact tominimise visual impact on the Darwin community.Light emanating from the plant at night could have impacts on visual amenity (detract from the nightsky) and attract migrating fauna (which might interfere with nesting, for example). The proponentacknowledges that it did not assess this issue for the previous EIS nor for the current PER; however, ithas undertaken to investigate, during the detailed design stage, opportunities to minimise light spill atnight.

4.18 Socio-Economic Impacts

4.18.1 Construction Work-force

The PER indicates that one of the key benefits of this proposal will be socio-economic, withapproximately 25% of the work-force sourced from Darwin. The remainder, comprising workers withparticular expertise that is not available in Darwin, will need to be brought in from other areas.

In 2001, the proponent had its contractor address the local labour market for its constructionworkforce. Conclusions were drawn concerning the availability of skilled workers in the local labourmarket using qualitative and limited quantitative data. It is envisioned that the proponent willcommission a skills audit of the Darwin area in the near future to update the previously acquiredinformation. Data obtained from the skills audit will be compared to the anticipated required craftlevels and any shortfalls will become evident and quantifiable at that time.

Another major factor in the proponent’s 25% estimate is that there will likely be a local labourshortfall for this project because of other competing local projects. In 2001 the potential localcompeting projects were identified as the following: Subsea Gas Pipeline ($ 525 million, start 2003),Darwin Port Development ($66 million, start 2003), Darwin to Moomba Pipeline ($550 million, start


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2002), and Darwin to Alice Springs Rail Link ($990 million, start 2001). The proponent concludedthat these other projects will likely result in strong competition for locally available skilled labour.Conversely, if any of these projects do not happen as anticipated, this could make more local labouravailable for the LNG Facility project.

4.18.2 Impacts on Commercial and Recreational Fishing in Darwin Harbour

The PER acknowledges that Darwin Harbour is closed to commercial haul net fishing and commercialmud crab fishing, but that limited gill netting and line fishing are permitted. It also recognises theimportant recreational resource Darwin Harbour represents to the people of Darwin, other Territoriansand tourists.

The PER also recognises that a favoured fishing area occurs off the northern tip of Wickham Point,which will not be affected by the LNG plant (i.e. there will be no restriction of fishing in this area).Similarly, there will be no restricti`on of access to landing in the region of the old leprosarium. Theonly restrictions to fishing will be adjacent to the loading jetty and construction dock (both of whichare well away from the area of greatest fishing interest) and within 500 m of LNG vessels approachingor departing the jetty.

One submission raised the issue of potential impacts on recreational fishing yields, from the noise ofLNG carriers (vessels).

In response, the proponent indicated that it is unaware of any research which links reduced fish catchrates to increased vessel traffic within harbours. It suggested that the low intensity noise levelsgenerated by slow-moving ships on approach to or departure from the jetty are likely to be much lessintrusive and disturbing to fish than the high intensity noise levels associated with recreational fishingvessels travelling at high-speed.

The fact that fish are regularly caught off the jetties and breakwaters of Darwin Harbour (whichcontains a significant commercial port) would suggest that ship movements do not deter fish. Theload out jetty might provide shelter to recreational fish and act as an artificial reef, especially oncecorals and other organisms colonise the structure and increase its habitat complexity.

Given that a 500 m exclusion zone will be set around the load-out terminal, fishing will be prohibitednear the jetty. As such, the restricted area is likely to act as a refuge for fish with habitats within thisarea. This effect has been noted in the vicinity of many offshore oil and gas installations and the LNGand condensate jetties in Dampier associated with the Northwest Shelf LNG project.

4.19 Cultural Impacts

4.19.1 Discovery of Archaeological/Heritage Places and Objects

The PER identifies the archaeological sites that were previously recorded (as part of the originalassessment for the EIS) within the proposed LNG Plant area and others that have been discoveredsince. The additional archaeological sites were reported to OEH and investigated in consultation withHeritage Conservation Services (within OEH). Two preliminary reports were consequently prepared,and a third is currently being prepared by a heritage sub-consultant. The proponent will ensure thatcopies of all reports will be forwarded to the Manager of Heritage Conservation, as required under theHeritage Conservation Act.

The PER refers to recently discovered shell middens MA19, MA20, MA21, MA22 and MA23. ThePER states that stone artefacts were not located in association with these sites; however, a site


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inspection conducted by the OEH in 2001 found several stone artefacts at these sites. Ministerialapproval may be needed if such features are to be disturbed or destroyed. Under the HeritageConservation Act, the proponent must inform OEH of any new archaeological sites or featuresdiscovered prior to or during the construction and operational phases of the project.

The PER has acknowledged that additional archaeological sites may be uncovered duringconstruction. The proponent, however, does not outline in detail appropriate procedures to befollowed in this event (although it is noted that the Darwin LNG Plant Draft EMP (Effect LNGP 8)does address this issue to a limited extent).

The proponent is working with OEH to establish an Archaeological Sites Register for Wickham Pointand a comprehensive procedure for the discovery of archaeological sites. This will be completed bythe proponent and endorsed by OEH during completion of the Construction EMP. The proponent issupportive of the proposal to have an archaeologist on-site during initial land clearing, or alternativelybe on alert to enable a rapid response and assessment should any additional sites or objects bediscovered during clearing activities.

Other procedures will include that

� OEH will be immediately notified of any archaeological sites discovered during site preparationand construction; and

� Vegetation clearing and other threatening activity will cease in the area of the site until OEH has achance to inspect the newly-discovered site and advise on when/how the threatening activity canrecommence.

4.19.2 Aboriginal Sacred Sites

The proponent has undertaken to consult with the Aboriginal Areas Protection Authority (AAPA) andconfirm that no sacred sites will be affected by the proposed expansion (to a 10 MTPA facility).

The proponent has indicated its intention to establish a “Heritage Issues Committee”, comprisingrepresentatives from OEH, AAPA and the Larrakia Association, to act as an advisory body forprocedures regarding sacred sites on Wickham Point. The proponent will consult with the AAPA onan ongoing basis prior to and during the construction phase.

An Authority Certificate issued to the proponent in 1997 identified four sacred sites (in DarwinHarbour) to be avoided; however, that Certificate has lapsed. The proponent has indicated that it willensure that a current Certificate is obtained from AAPA prior to initiating any on-site works.

4.20 Other Issues

4.20.1 Mercury in Domestic (Industrial) Gas

To protect equipment at the plant, the proponent will remove mercury from the natural gas streambefore it enters the refrigeration system (to liquefy the gas); however, before this treatment occurs, gasfor domestic supply would be diverted to another pipeline.

One submission queried how domestic industrial users (and equipment/structures to deliver domesticgas) would be protected from potential impacts of mercury in the delivered product.

In its response to submissions, the proponent indicated that mercury concentrations in the gas from theoffshore producers are expected to be very low (less than 0.6 micrograms per normal cubic metre) andtherefore are currently within the gas specification required for delivery to domestic gas purchasers. Amercury guard bed, similar to what will be installed at the LNG plant, could be installed on the


May 200238

domestic gas stream if additional mercury removal were required in the future. This additionaltreatment would be determined by the terms and conditions of any subsequent sales contract.

4.20.2 Requirements for Fill (during construction phase)

In reviewing the Litchfield Shire’s Seasonally Waterlogged Soils Map, the proponent recognised thatthe area of the development footprint most prone to waterlogging will be mainly the intertidal areaslocated on the perimeter of the proposed plant site. Most of the plant site itself is not prone towaterlogging, except in an area currently dominated by Pandanus swamp. Given that an all-weatheraccess road will be completed to the site prior to construction works commencing, and that on-site fillmaterial will be available to raise the level of the swamp, the proponent considers it unnecessary toimport fill material, and proposes to use fill material cut from the site. Rock fill, however, will berequired for purposes of armouring the load-out jetty groyne and construction dock, and the proponentplans to import this material from quarries located near Darwin.

4.20.3 Erosion and Sedimentation

The proponent has indicated that it will submit a draft Erosion and Sedimentation Control Plan toDIPE for approval prior to any construction works. This Plan will confirm key drainage flows acrossthe site and specify a range of management measures to minimise erosion and siltation of thesurrounding environment during plant construction and operation. Control measures such as silt trapswill be established based on advice received from DIPE.

4.20.4 Acid sulfate soils

The proponent has undertaken to prepare an Acid Sulfate Soil Management Plan as part of the EMPprocess, which will include those areas affected by the proposed expansion. This will involve ground-truthing to confirm those areas on-site that may be at risk from acid sulfate soil characteristics, andpreparation of a comprehensive set of management procedures detailed in the plan to be adhered to bythe construction contractor. The proponent will submit the Plan to DIPE for review and endorsementprior to the commencement of construction activities.

Recommendation 13

As part of the proponent’s Environmental Management Program, an Acid Sulfate SoilManagement Plan shall be prepared in consultation with relevant NT Government agencies.Sampling and analysis of potential acid sulfate soils shall be conducted as part of preparing thePlan. The Plan shall include monitoring of leachate from any soil or spoil retention areas andreclamation areas, and contingency measures in the event leachate is found to be excessivelyacidic.


4.20.5 Anticipated Freshwater Usage (during construction phase)

Although the proponent is requesting that a water line capable of supplying 80m3/hour be available forthe construction phase, the water will not flow continually during construction at its maximum rate.During construction the water supplied by PAWA will primarily be used for personnel needs (drinkingwater etc.), the mixing of concrete and for dust suppression. It will also be available for firesuppression.

Preliminary estimates provided by the proponent’s contractor indicate peak average daily water usagemay amount to approximately 680 m3/day, excluding that required for LNG tank hydrotesting. Based


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on this figure, the following feasible scenario of daily water usage is offered, which will be confirmedduring detailed design:

� Personnel drinking water – 6 m3;

� Personnel sanitary water – 85 m3;

� Concrete mixing water – 455 m3; and

� Dust/fire suppression water –135 m3.

The drinking water will be consumed, the sanitary sewage/water will be removed from the site, thewater used for concrete mixing will hydrate from the concrete during curing, and the water used fordust suppression will evaporate.

In the PER, the proponent indicated that there will be no point-source discharges of wastewater to theHarbour from construction activities or temporary facilities during the construction phase. Prior tocommissioning of the facility, freshwater is likely to be used to hydrotest tanks and piping. In advanceof this activity, maximum water flows could occur for a time as water is accumulated at the site forhydrotesting. (Discharge of hydrotest water is described in Section 4.7.2 above.)

4.20.6 Fuel Storage

The proponent has indicated that fuel storage at the facility will fully comply with AS 1940(Australian Standards Australia 1993) requirements for the storage and handling of flammable andcombustible liquids on-site. This will ensure that the best industry methods of handling on-site fuelstorage are adopted, including the capacity of bunds to fully contain the largest potential spill,inclusion of properly-sited and maintained sumps, and comprehensive inspection and emergencyresponse procedures and pumping systems. The proponent has also indicated that it will liaise with theNT Government to ensure that all local requirements are met for safe construction and storage of fuelsrequired for the Darwin LNG Project.

4.21 Sustainability

In the PER, the proponent indicates that the EMP will address sustainability issues in a “triple bottomline” approach, integrating environmental, social/cultural and economic factors. As described inSection 4.12 of this Assessment Report, the proponent sees the main threat of serious or irreversibleenvironmental damage posed by the project would be from a shipping accident in the Harbour whichcould result in widespread oil spillage and mortality of mangroves and associated biota. The risk,however, will be mitigated by controls on navigation, the double-hulled design of vessels, and oil spillcontingency plans to be prepared by the proponent and included in the EMP. The proponent alsosupports its view that the risk of an oil spill is low by citing the safety record of LNG vessels (detailedin Appendix G of the PER).

The proponent indicates that the project will not threaten any populations of rare or endangeredspecies, nor threaten currently designated conservation reserves in the Darwin region. The proponentplans to mitigate the loss of dry rainforest habitat at Wickham Point by ensuring the protection of asuitable portion of that habitat elsewhere.

For all of the above reasons, the proponent believes the expansion of the LNG project from a 3 MTPAplant to a 10 MTPA facility is consistent with the principles of Ecologically Sustainable Development.The proponent points out (in the PER) that, with the exception of greater atmospheric emissions, theenvironmental costs of the larger plant are generally the same for both proposals.


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In the EMP, the environmental, social and economic factors that define the sustainability of the LNGproject will become Key Result Areas (KRAs) for the project, with Key Performance Indicators(KPIs) determined for each factor. These KRAs and KPIs will then form part of the business planningprocess for the project to be adopted by the proponent. They will also provide the basis ofcommunicating the company’s goals, objectives and performance measures with the Darwincommunity through a public Sustainability Reporting process.


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5 ENVIRONMENTAL MANAGEMENT PROGRAM

5.1 Introduction

This section of the PER confirms the environmental management commitments made by theproponent and recommendations made by the NT Government as an outcome of the previousenvironmental impact assessment for the 3 MTPA LNG plant (1998). It also identifies additionalcommitments and recommendations to address the potential environmental impacts of the proposedexpansion, taking into account the environmental studies done subsequent to completion of theoriginal assessment.

5.2 Preliminary EMP (Dames and Moore, 1998b)

The Preliminary EMP prepared in 1998 included the following components (based on key projectactivities) that are relevant to the current 10 MTPA proposal:

� Dredge and Spoil Management Plan;� LNG Plant Environment Plan;� Emergency Response Manuals;� Oil Spill Contingency Plans;� Corporate Relations Plan; and� Compliance Auditing and Reporting Plan.

The Preliminary EMP committed the proponent to developing and implementing a detailedEnvironmental Monitoring Program for the following:

� Abundance of weeds and feral animals outside the disturbed “footprint” of Wickham Point;� Abundance of biting insects within the footprint;� Effects of dredging for the loading jetty and construction dock on the corals of Channel Island

and Wickham Point;� Productivity of mangroves adjacent to the plant site;� Quantity, quality and methods of disposal of construction and operational wastes;� Confirmation of the quantity and quality of atmospheric emissions;� Wastewater discharge volumes and quality, including effluent dispersal studies;� Concentrations of selected metals, TBT and total petroleum hydrocarbons in marine sediments

and selected marine biota in areas to be dredged; and� Contribution to the DPC’s monitoring program for introduced marine organisms.

5.3 Revised Environmental Management Program

For the 10 MTPA plant, the proponent indicated its intention to build on commitments of thePreliminary EMP in development of management plans for both the construction and operationalphases.

The proponent has undertaken to address the specific requirements of this Environmental AssessmentReport, which are based on review of comments from the public and relevant NT Governmentagencies. The proponent also indicated that the final EMP will be based on all matters involvingregulatory compliance as well as corporate requirements to ensure the facility has an appropriate andeffective Health, Safety and Environmental Management System.


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Section 5 of the PER identifies a number of community relations groups and liaison committeesthrough which various stakeholders may be able to provide input into the EMP.

The final EMP will be a public document.

Completion of the EMP will involve reviewing the original commitments for their applicability.Preparation of the final plans, extended from those outlined in the Preliminary EMP, will incorporateconsideration of the additional level of risk associated with the expanded project and commentsreceived from the NT Government and Environment Australia. (Environment Australia will considerrecommendations in this Assessment Report in completing their assessment under the EnvironmentProtection [Impact of Proposals] Act) 1974.

Recommendation 14

In preparing the Environmental Management Program, the proponent shall include anyadditional measures for environmental protection and monitoring contained inrecommendations made by the Northern Territory and Commonwealth Governments withrespect to the proposal. The EMP shall be referred to relevant NT agencies and EnvironmentAustralia for review prior to finalisation, after which it shall become a public document. TheEMP shall form the basis for approvals and licences issued under relevant NT legislation.


5.3.1 Additions to Commitments in the 3 MTPA EMP

The outcomes of the updated assessment studies done for the PER confirm that most of the anticipatedenvironmental effects of the proposed 10 MTPA plant are essentially the same as those for the original3 MTPA proposal. For this reason, the commitments detailed in the Preliminary EMP adequatelyaddress the majority of anticipated effects of the project on biophysical, cultural and socio-economicenvironments.

In addition to the plans and manuals in the Preliminary EMP, the PER indicates that the proponent willinclude the following commitments in the final EMP to address the potential environmental impactsassociated with the expanded 10 MTPA facility:

1. Atmospheric emissions – The proponent will quantify major emission sources duringcommissioning, by periodic testing programs. Results will be used to develop a monitoring systemfor NOx from key emission sources. (NOx is the most likely pollutant to approach ambient NEPMlimits.)

2. Greenhouse gas emissions – As part of its commitment to the Commonwealth Government’sGreenhouse Challenge Program, the proponent will develop a Cooperative Agreement with theAustralian Greenhouse Office, including commitments for continual improvement in energyefficiency, development of a comprehensive greenhouse gas management strategy and actionplans for mitigation measures incorporated into the design of the revised project. In addition toconsideration of plantation sequestration options, the proponent will evaluate other options duringthe design and construction phases, with periodic reviews during the operational phase.

3. Wastewater discharge – Treated wastewater will be used on-site for irrigation, to minimise directdischarge into the Harbour, except on a contingency basis (e.g. if ground is saturated during heavywet season rains). During preparation of the final EMP, the proponent will analyse the potentialadditives to hydrotest water, their fate upon discharge to the Harbour and potential impacts onbiota. Proposed mitigation measures will be subject to approval by DIPE.

4. Waste management – To handle the increased levels of solid and semi-liquid wastes anticipatedfrom the expanded plant design, proposed management measures have been revised to complywith the Waste Management and Pollution Control Act, which was not in force when the previous


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3 MTPA proposal was developed and assessed. To reduce generation of wastes, opportunities forrecycling and waste minimisation will be sought for all project operations.

5. Clearing of dry rainforest – The proponent has undertaken to continue consultations with DIPEto identify a suitable area of dry rainforest in the Darwin region to be acquired for conservationand offset the loss of this significant habitat within the footprint of the facility.

6. Fauna corridors – The proponent expects that most animals will be able to traverse the landwardend of the construction dock at night during the construction period, and at any time thereafter.The proponent will mitigate the effect of the barrier presented by the construction groyne at thehigh tide level by constructing earth ramps on either side of the groyne, if deemed necessary byDIPE.

7. Public risks – A Qualitative Hazard Analysis and Risk Assessment for the 10 MTPA proposaldemonstrated that the siting, design, construction and operation of the proposed LNG plant willadequately protect persons, property and the environment. During the detailed design phase, theproponent will complete the following:

� A final HAZOP (Hazard and Operability) Study, to identify potential scenarios arising from thefailure of valves and controls or other upset conditions;

� A final QRA (Quantitative Risk Assessment), to identify, assess, evaluate and manage potentialrisks associated with the project; and

� A detailed Safety Report for the LNG plant, in accordance with relevant Worksafe AustraliaStandards and prepared on the basis of the HAZOP and QRA studies outlined above.

8. Sustainability framework – The proponent has undertaken to integrate the principles ofEcologically Sustainable Development (ESD) into the environmental, social and economicaspects of the project by developing a “Sustainability Framework.” This will allow a systematicapproach for the proponent to maximise and track its performance in the design, constructionand operation of the facility.

5.3.2 Summary of Updated Environmental Management Commitments

Appendix 4 summarises the updated commitments made by the proponent (in addition torecommendations by the NT Government), taking into account the additional measures indicatedabove. Issues dealing specifically with the Bayu-Undan to Wickham Point pipeline have not beenincluded, as they were fully considered in the previous assessment and do not apply to the currentproposal to expand the land-based facility.

5.3.3 Revised Environmental Management Plans (to be included in the proponent’s EMP)

5.3.3.1 Dredging and Spoil Management Plan

The proponent will prepare a Dredging and Spoil Management Plan that addresses potentialenvironmental impacts and includes measures to ensure protection of the marine biota of DarwinHarbour (in particular the corals at Channel Island), and nearby aquaculture facilities. The measureswill be incorporated into a Reactive Monitoring Program (RMP) that includes identification ofbaseline conditions, turbidity monitoring, a reactive coral monitoring program (if required), andcontingency measures to be implemented if monitoring indicates adverse impacts. Development ofthe RMP will be done in consultation with relevant NT Government agencies.


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5.3.3.2 LNG Plant EMP

The LNG Plant EMP will include specific management and monitoring actions to be implemented bythe proponent to achieve sound environmental management of the plant site and will build on priorcommitments made for the 3 MTPA facility. Potential impacts and proposed mitigation strategies willinclude all phases of the plant’s life, i.e. site preparation, construction of plant, plant operation andpost-operation.

The key environmental management issues include

� Minimisation of environmental disturbance associated with development of the plant andprotection of surrounding undisturbed areas;

� Protection of remaining dry rainforest, mangroves and faunal habitat;

� Management of weeds, feral animals and bushfires;

� Protection of undisturbed archaeological and heritage sites;

� Minimisation of mangrove mud disturbance and management of actual or potential acid sulfatesoils;

� Management of biting insects;

� Management of wastes and discharges resulting from construction and operation;

� Minimisation of gaseous emissions;

� Training and education of the workforce in relation to environmental management objectives; and

� Minimisation of adverse socio-economic impacts on the people of Darwin, includingestablishment of community liaison mechanisms.

5.3.3.3 Emergency Responses

Emergency Response Manuals (ERMs)

The proponent will prepare emergency response manuals to cover the conceivable emergencysituations at the plant and marine terminal, including situations off-site that could impact thesefacilities. The proponent will liaise with appropriate civil and port authorities to develop anemergency plan for the entire facility, to assist in continual review of the plan and procedures, to planand run joint training and emergency exercises, and to develop effective and efficient communicationsduring an emergency.

Cyclone Response Procedures

The proponent recognises that cyclonic activity in the area will require the preparation of appropriatecontingency plan for this event. The proponent will develop these cyclone procedures in consultationwith the Darwin Port Corporation, NT Emergency Services and other government agencies involvedin emergency management for the Darwin area. These procedures will also be developed byconsulting established plans in place for these same events at existing facilities the proponent operatesin other tropical areas, particularly the South China Sea and the Gulf of Mexico. The goal of theseplans will be to ensure a well-defined procedure is in place for safety shutdown and to secure thefacility as required by the movement of tropical cyclones to mitigate risk to employees, the generalpublic, and the facility from these events. Appropriate cyclone shelters and evacuation plans will be inplace for all facility personnel during the construction and operational phases of the facility and will beregularly reviewed to insure the plan is kept up-to-date.


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A cyclone emergency plan will be developed to address what steps the plant will go through to securethe process area. The goal of the plan will be to leave the plant in such a state that if damage to theplant occurs as a result of a cyclone, the risk of a fire/explosion is minimised, e.g. when a cyclone isimminent, the plant will be shutdown and hydrocarbon inventory will be minimised. The infrastructureat the facility will be designed to appropriate standards to minimise the risk of significant damagefrom cyclones.

5.3.3.4 Oil Spill Contingency Plans (OSCPs)

As described in Section 4.12 of this Assessment report, the proponent indicated that it will prepare oilspill contingency plans to enable an effective response to an oil spill during the construction andoperational phases of the project. During the construction phase, potential spills could arise fromincidents involving dredges or vessels using the construction dock or loading jetty. During operations,spills could result from accidents involving LNG carriers or spillages at the loading jetty.

The OSCP for the LNG facility will be developed in consultation with the DPC and other relevantauthorities, and integrated into existing Darwin Harbour OSCP.

5.3.3.5 Corporate Relations Management Plan

The proponent has developed a Corporate Relations Plan to ensure that the local community isinformed about construction and operational activities and that key stakeholders have ready access torelevant information and personnel. The Plan will establish the following:

� A Corporate Relations Manager and Department;

� A Public and Community Relations Program;

� A Larrakia Liaison Committee;

� A CASA/Air Service Australia Liaison Link; and

� An internet web site.

5.3.3.6 Compliance auditing and reporting

In the PER, the proponent restated the commitment it made in the Preliminary EMP to be responsiblefor regular audits and reviews of the LNG facility’s environmental and safety management, includingboth on-site auditing and review of performance reports.

Additional inspections and investigations will be done in the event of significant environmentalincidents, in conjunction with relevant government agencies. The proponent will also meetrequirements under the Waste Management and Pollution Control Act for any additional monitoringand reporting.

The proponent has undertaken to produce an annual audit report to DBIRD, DIPE and EnvironmentAustralia (as required) and a have a triennial review of the EMP. The proponent also intends to dointernal environmental audits of the site, to enable managers to assess the day-to-day environmentalmanagement of activities at the site, including all aspects of operations that result in emissions,effluent or wastes. In addition, the proponent will do regular audits of its Environmental ManagementSystem, involving assessment of the objectives, organisational structure, responsibilities, procedures,processes and resources available at the site.

The above auditing activities will facilitate the proponent’s commitment to provide annual greenhouseand energy efficiency reports as part of its Cooperative Agreement under the Greenhouse ChallengeProgram and as part of its framework for public sustainability reporting.


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5.3.3.7 Decommissioning

The proponent has indicated that, at the end of the project life (estimated to be 20-25 years, with thepossibility of extension if future gas reserves are available), the plant will be decommissioned inaccordance with standard practice applicable at the time. Plant equipment and piping will be purgedof hydrocarbons, and plant and office equipment will be sold or disassembled and sold as scrap, ordisposed of in accordance with regulatory guidelines. Regulatory guidelines will also be followed forthe dismantling of the construction dock and product-loading jetty.

The proponent has also undertaken to rehabilitate the site in consultation with the NT Government, ifthe site is not sold and will not be utilised for other purposes.

Recommendation 15

The proponent shall ensure that decommissioning is done according to the best environmentalstandards available at the time.

[ = Recommendation 20 of Assessment Report No. 24]


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6 CONCLUSIONS

The Office of Environment and Heritage (OEH) considers that the environmental issues associatedwith the proposed project have been adequately identified. Appropriate environmental management ofsome of these issues has been identified through the assessment process, whereas resolution of othermatters will be achieved through monitoring and management actions detailed in a comprehensiveEnvironmental Management Program (EMP).

In November 1998, a Preliminary EMP was produced (for the 3 MTPA proposal) which incorporatedcomments by and approval conditions set by the Commonwealth and NT Governments, based on theirreview of the Supplement to the Draft EIS (Dames and Moore 1998a). The proponent plans tocomplete the EMP for the 10 MTPA facility in stages, before the start of construction, by building onthe commitments in the Preliminary EMP (Dames and Moore 1998b) and focusing on the additionallevel of potential environmental impacts associated with the expanded project. Comments submittedby the public and Northern Territory Government during the review of the PER will also be used todevelop new mitigation measures for impacts associated with the proposed expansion or to revise,where appropriate, those developed for the 3 MTPA plant.

This final EMP will be subject to review and approval by relevant Northern Territory andCommonwealth Government agencies.

The EMP will be the major vehicle for implementing management and monitoring commitments madeby the proponent in the PER and the recommendations detailed in this Assessment Report. As such, itwill be a working document for the life of the plant and it will require continual review in the light ofoperational experience and changed circumstances.

The proposed expansion will have two main environmental impacts during the construction andcommissioning stages of development:

� the clearing of an additional 21.6 ha of regionally-significant dry rainforest (monsoon vinethicket) which comprises a 47% increase over clearing for the 3 MTPA plant; and

� the discharge of an increased volume (not specified in the PER) of hydrotest water (possibly withchemical additives) from three LNG storage tanks instead of two and from a smaller tank forcondensate.

To offset the loss of dry rainforest, the proponent is working with the Department of Infrastructure,Planning and Environment (DIPE) to identify and acquire another area of equivalent or better qualityrainforest for conservation.

To mitigate potential impacts on marine biota from discharge of hydrotest water, the proponent hasundertaken to work with OEH to identify appropriate treatment and release options (e.g. dilutionbefore release, release during tidal phases that will promote further dilution and transport out of theHarbour, release at a slow rate, etc.). If analysis of the proposed formulation of hydrotest waterindicates a significant potential for toxic impacts on marine life, the proponent will need to obtain aWaste Discharge Licence from OEH to release this water into Darwin Harbour and must comply withall conditions attached to that Licence.

During the operational life of the facility, the expanded development will also have several significanton-going environmental impacts:

� Perhaps the most significant of these will be a 2.5x increase in greenhouse gas emissions,particularly CO2.


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Section 4.5 of this Assessment Report discusses the implications of the increased production ofCO2, and a number of mitigating actions will be undertaken by the proponent in order to reduce oroffset the production of this greenhouse gas as the operation proceeds. (The plant will alsoproduce a number of other atmospheric pollutants; however, the proponent’s modelling of “worst-case” scenarios indicates that these will be kept within national and international guideline levels.)

� Another significant potential impact associated with the proposed expansion is an increased riskfor groundings, collisions or other incidents from the near doubling of visits by LNG vessels(especially the risk of oil spills).

At peak production, vessels will berth and load LNG every two to three days (instead of once perweek, for the 3 MTPA facility). The Hazard and Risk Assessment for shipping concluded that theestablished design, construction and operating practices of LNG vessels, combined with theDarwin Port Corporation controls and safety measures, will ensure that the risk of a major incidentresulting in spills from an LNG vessel will be very small. The increased shipping is thereforeconsidered to pose minimal additional risk compared to that for the 3 MTPA facility.

Despite the low risk, the proponent will develop site-specific oil spill contingency plans (OSCPs)for the construction and operation phases of the project. These OSCPs will integrate effectivelywith the Darwin Harbour OSCP, the Commonwealth’s National Plan to Combat Pollution of theSea by Oil and other Noxious and Hazardous Substances and will identify options to utiliseexpertise and equipment from the industry-based Australian Marine Oil Spill Centre (Geelong).

� A third source of increased public and environmental risk will be from increased production (10instead of 3 MTPA) and a near doubling of volumes of LNG in storage tanks at Wickham Point.

The increased risk to people, the environment and adjacent facilities from potential incidentsrelating to increased production and storage of LNG was addressed in a Hazard and RiskAssessment study and report (Bechtel 2002, Appendix G of the PER). This report focuses on themain changes in risk profile between the 3 MTPA and 10 MTPA facilities: two LNG “trains” (i.e.production pathways and related infrastructure) instead of one; greater LNG storage capacity; andmore frequent shipping.

The Hazard and Risk Assessment concluded that the codes and standards governing the designand operations at the LNG plant will maintain, at an acceptably low level, potential hazards to sitepersonnel, the public and the environment. The remote location of the plant in relation toresidential areas provides a further safeguard to the public.

� Volumes of waste-water will increase nearly 2.5x, and solid and semi-liquid waste (e.g. domesticwaste, oils, sludge) will increase approximately 1.7x.

The proponent has undertaken to use treated wastewater for on-site irrigation. Discharge to theHarbour will be considered as a contingency option (e.g. during the wet season, if soils are alreadysaturated), and a Waste Discharge Licence would have to be obtained in advance from the Officeof Environment and Heritage.

The increased levels of solid and semi-liquid wastes were re-assessed, and the proponent’sanalysis indicates that the range and predicted volumes of non-hazardous and hazardous wastescan be appropriately managed and disposed of safely in accordance with the provisions of theWaste Management and Pollution Control Act. The LNG plant will require one or more licencesunder this Act and the Water Act to regulate emissions to air, management of wastes and anydischarges to Darwin Harbour. The proponent will be required to comply with all licenceconditions and regulations under these acts, including regular compliance audits and reports.


May 200249

Based on its review of the PER and the proponent’s Response to Submissions from relevant NTGovernment agencies and the public, the Office of Environment and Heritage considers that theproject can be developed and managed in a manner that avoids unacceptable environmental impacts,provided that the environmental commitments, safeguards and recommendations detailed in thisAssessment Report and in the final EMP are implemented, and regular compliance auditing andreporting are undertaken.


May 200250

REFERENCES

ANZECC/ARMCANZ. 2000. Australian and New Zealand Guidelines for Sewerage Systems – Useof Reclaimed Water. National Water Quality Management Strategy. Australia & New ZealandEnvironment and Conservation Council and Agriculture & Resource Management Council ofAustralia and New Zealand, Canberra.

ANZECC/ARMCANZ. 2002. Australian and New Zealand Guidelines for Fresh and Marine WaterQuality. National Water Quality Management Strategy. Australia & New ZealandEnvironment and Conservation Council and Agriculture & Resource Management Council ofAustralia and New Zealand, Canberra.

Australian Standards Australia. 1989. SAA Code: Dead and Live Loads and Load Combinations,AS 1170.1. North Sydney: Standards Australia.

Australian Standards Australia. 1993. SAA Code: The Storage and Handling of flammable andCombustible Liquids, AS 1940. North Sydney: Standards Australia.

Dames and Moore. 1997. Darwin LNG Plant. Draft Environmental Impact Statement. Reportprepared for Phillips Oil Company Australia. Report No. R635.

Dames and Moore. 1998a. Darwin LNG Plant. Supplement to Draft Environmental ImpactStatement. Report prepared for Phillips Oil Company Australia. Report No. R657.

Dames and Moore. 1998b. Darwin LNG Plant. Preliminary Environmental ManagementProgramme. Prepared for Phillips Oil Company Australia. Report No. R683.

DBIRD. 2002. Guideline for Application for Approval to Dispose of Petroleum Related NORM - EG506. NT Department of Business, Industry and Resource Development.

Darwin City Council. 1995. Waste Management Strategy: Towards 2000.

DLPE. 1992. Litchfield Area Plan. NT Department of Lands, Planning and Environment.

DLPE. 2000. National Pollutant Inventory. Diffuse Water Emissions Study – Darwin Harbour andSurrounding Catchments. Report no. 30/2000D. NT Department of Lands, Planning andEnvironment.

DLPE. 2001a. Proposed Litchfield Planning Concepts and Land Use Objectives 2001. NTDepartment of Lands, Planning and Environment.

DLPE. 2001b. Darwin Air Emission Inventory. NT Department of Lands, Planning andEnvironment.

DLPE. 2001c. National Environment Protection Measure for Ambient Air Quality – Monitoring Planfor the Northern Territory. NT Department of Lands, Planning and Environment.

Hanley, R. 1988. Invertebrate fauna of marine habitats in Darwin Harbour. In: Larson, HK, Michie,MG & Hanley, JR (eds.) Darwin Harbour: Proceedings of a Workshop on Research andManagement held in Darwin, 2-3 September, 1987. Australian National University, NorthAustralia Research Unit, Mangrove monograph No. 4:135-152.


May 200251

NEPC. 1998. National Environment Protection Measure for Ambient Air Quality. NationalEnvironment Protection Council.

NHMRC. 1986. National Guidelines for Control of Emission of Air Pollutants. National Health andMedical Research Council.

Padovan, A. 1997. The Water Quality of Darwin Harbour, October 1990 – November 1991. ReportNo. 34/1997D. NT Department of Lands, Planning & Environment.

Whelan, P. 1988. Construction practice near tidal areas in the Northern Territory: Guidelines toprevent mosquito breeding. NT Coastal Management Committee, Darwin.

WHO. 1999. Guidelines for Air Quality. World Health Organisation, Geneva.


May 200252

APPENDICES

1. LIST OF RESPONDENTS TO THE PER

2. ISSUES RAISED IN SUBMISSIONS

3. SUMMARY OF GOVERNMENT AND PUBLIC COMMENTS ONTHE PER

4. ENVIRONMENTAL COMMITMENTS AND SAFEGUARDS

APPENDIX 1


May 2002

52

LIST OF RESPONDENTS TO THE PER

SUBMISSIONNO. NAME ORGANISATION

STATE/TERRITORY

1 Norman Fry Northern Land Council NT

2 Gerry Wood MLA Member for Nelson NT

3 Kirsten Blair andMark Wakeham

Environment Centre NT NT

4 Rob Wesley-Smith Private submission NT

5 Margaret Clinch Planning Action Network NT

6 Scott Whiting Private submission NT

7 Rodney Wheeler Private submission NT

8 Duncan Dean Save Darwin HarbourGroup

NT

9 Jeff Butler Private submission NT

10 NT Government NT

APPENDIX 2


May 2002

53

ISSUES RAISED IN SUBMISSIONS

ISSUE RESPONDENT(Numbers refer to submissions in Appendix 1)

TOTAL

1 2 3 4 5 6 7 8 9 10

PLANNING:

Location of plant � � � � � � � 7Future expansion � � � 3Management of adjacent areasfor conservation � 1Zoning � � � 3WASTE MANAGEMENT &POLLUTION CONTROL:Hydrotest water (composition,risks from discharge) � � � � � 5Discharge of treated effluent(including sewage) & stormwater � � � � 4Sanitation facilities (constructionphase) � 1Irrigation with treatedwastewater � � � � � 5Wastewater recycling withinplant � 1Waste management (hazardous &non-hazardous; recycling) � � � 3Management of waste vegetation(construction phase) � 1Dredging � � 2Contamination on-site � 1Contamination of food fish � � 2Contamination of DarwinHarbour � � � � 4Atmospheric emissions (adequacyof modelling, acid rain, smog,odours)

� � � � � 5

Greenhouse gas emissions(quantification, offsets & re-injection)

� � � � � � � 7

Visual impacts (amenity &lighting) � � � � 4Noise � � � 3ECOLOGICAL IMPACTS:

Dry rainforest (removal,mitigation & offset areas) � � 2Mangroves (removal/disposal &monitoring) � 1Dugongs, dolphins, turtles, fish &birds (including threatened &vulnerable species)

� � � � 4

Fauna corridors � 1Fire, weeds and feral animals � 1Modelling for long term impacts � 1

1 2 3 4 5 6 7 8 9 10

APPENDIX 2


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54

1 2 3 4 5 6 7 8 9 10

HAZARDS & RISKS:

Cyclones, earthquakes, lightningstrikes & storm-urge � � � � � 5Public risk � � 2Shipping risk (grounding,collision, oil spills & exoticmarine pests)

� � � � � 5

Aviation risks (from flares) � � � � � � � � 8Terrorist act � 1OTHER ISSUES:

Archaeological/Heritage sites &objects � � 2Aboriginal Sacred Sites &Authority Certificate � 1Impacts of rock groynes � 1Impacts on tourism � � 2Environmental ManagementProgram & Plans � � � � 4Restricted maritime access � � 2Utilities (power, water & fuel gas) � � � � 4Turbines (steam instead of gas &more efficient models) � � � 3East Timor (socio-economic &political issues) � � 2Inadequate time for public reviewof PER � 1Work health issues (includingbiting insects � � 2Pipeline issues � � 2Mercury in domestic (industrial)gas supply � 1Increased run-off to DarwinHarbour � 1Increased road traffic(construction phase) � 1Road transport of hazardouswaste � 1Erosion & sediment control � 1Acid sulfate soils � 1Fuel storage on-site � 1Environmental performance ofproponent’s other LNG plants � 1Size of construction workforce � 1Economic benefits for Darwin,the NT and the Commonwealth � � 2Flaring (other than potentialimpact on aviation) � 1Relocation of LPG production tooffshore � 1Financial responsibility fordisasters or environmentaldamage

� 1

Decommissioning/Rehabilitation � 1

APPENDIX 3


May 2002

55

SUMMARY OF GOVERNMENT AGENCY ANDPUBLIC COMMENTS ON THE PER

AUTHOR COMMENTSNTGOVERNMENT

� Request for reports on new archaeological discoveries associated withproject for site monitoring purposes.

� New discoveries to be reported to the Office of Environment andHeritage during site construction.

� Currently there are satisfactory protection and mitigation measures forall archaeological sites identified on site, which may be impacted by theproposal.

� Requirement to identify long term protection measures for the remnantsof the Mud Island Leprosarium. (Site MA17)

� Requirement for reconfirmation of stated procedure (Effect No. LNGP8, Preliminary EMP 1998), regarding discovery of additionalarchaeological sites during construction phase.

� Recommend on-site archaeologist during site clearing activities foradvice on assessment and preliminary management of any culturalmaterial discovered.

� Archaeological sites register to be established and site managementcommitments to be provided in detail.

NTGOVERNMENT

� No special reference to Aboriginal sacred sites within the PER.� No Authority certificate currently applies to the project.� Phillips Company is advised to seek an Authority Certificate for the

project.

NTGOVERNMENT

� Acquiring dry rainforest as a greenhouse emissions offset mitigationmeasure requires further consideration, especially in relation to longterm land management issues.

� In addition to vegetation sinks and geological sequestration, it issuggested that non-vegetation related greenhouse offset options beinvestigated by the proponent. Offset projects related to the NT wouldbe appropriate.

� All cleared vegetation should be used for revegetation.� Management of waste vegetation should avoid potential greenhouse

emissions caused by stockpiling vegetation.� Increased SO2 emissions and the potential environmental impacts on the

local environment require more discussion.� Reasons for including acid gas incinerator and hence increasing SO2

emissions not clearly explained.� Air monitoring for the project could include SO2.

NTGOVERNMENT

� Deforestation abatement is not a Kyoto option but has the potential to bea domestic trading option.

� Oil mallee carbon offsets over pine and eucalypt plantations maychange over time due to Australia’s ratification position (Kyoto) andfuture carbon accounting modalities.

� Overall offset studies accurate but limited in scope.� Post Kyoto ratification price for CO2 equivalents is likely to be higher

due to demand.� Proposed mitigation options (waste heat recovery, ship vapour recovery,

upgrade of the frame 5D turbines) are all likely to be profitabilityefficiency improvements of which greenhouse abatement is a favourableconsequence. They should not be considered mitigation options.

APPENDIX 3


May 2002

56

� Use of high nitrogen content fuel would reduce NOx concentrations butthe greenhouse implications of this are not clear. NOx is not listed as agreenhouse gas.

� Greenhouse emissions from the plant are estimated to be 4.6 Mt of CO2equivalent annually or approximately 50% of NT emissions and 1% ofAustralia’s annual emissions.

� No legally binding emissions restrictions if Australia does not ratifyKyoto Protocol.

NTGOVERNMENT

� Identify type of hydrotest water (whether seawater or freshwater) andestablish monitoring techniques, which will ensure compliance withdischarge threshold criteria.

� Potential impacts of mercury in domestic gas supply.� Request for average anticipated water use during construction stage and

wastewater treatment strategies including treatment and monitoring ofchemicals entering the CPI oil in water separator unit.

� Impacts of noise from jetty pile installation on behaviour of local fauna.� Request to recheck SO2 calculations in PER.� SO2 emissions from plant have a maximum design concentration of 706

TPA rather than the 141 TPA modelled. It is recommended thatvariation in feed gas on SO2 emissions be addressed by the proponent.

� Variation in feed gas and associated emissions should be modelled andcompared to threshold triggers in the National EnvironmentalProtection Measure for Ambient Air Quality.

� Suggestion that modelling be revised for predicted emission scenarios,including those for maximum design capacities.

� Waste disposal options discussed may not be available for the durationof the project. Alternative disposal options should be considered. Hasconsultation with local disposal facilities been conducted regardingfuture capacity to accept estimated waste volumes?

� Do waste figures per annum take into account the construction phase?� What arrangements have been made to dispose of spent amine?� If activated carbon beds are to be disposed of to landfill who will

maintain responsibility for any contamination issues arising in thefuture? In addition, what alternative options are available for treatment/disposal of carbon beds?

� Weeds may be come a problem in cleared areas outside the siteboundary due to increased human activity and importation of othermaterials from outside the area.

� Proponent will need to comply with the Weed Management Act and anyweed management plan that may be approved for the region, district orshire, including the Wickham point area. The proponent acknowledgesthis issue and is preparing a site management plan, which includesvehicle wash-down and inspection procedures.

� Water quality impacts of dredging may impact the activities of theDarwin Aquaculture Centre (DAC). Small changes in water quality andsediment load may affect DAC experiments and production. The DACrequests to be advised when dredging will commence so it mayimplement measures to minimise potential impacts on its activities.

� Water quality is critical to the DAC; therefore, the DAC requests adviceon discharge of wastewater, water quality and discharge volumes.

� The DAC is relatively close to the new development and is taking waterfrom the harbour. Information on the exact chemicals to be added tohydrotest water would be appreciated.

� The DAC requests advice on discharge of hydrotest water and timing,so preventative measures and monitoring may be conducted.

� Runoff volumes from the site have not been provided. Runoff volumes,if considerable, may impact water quality.

APPENDIX 3


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57

� If increased sediment loads impact water quality at the DAC’soperations, the proponent may want to consider upgrading the Centre’sfiltration system, as part of their environmental management program.

� Each LNG tanker entering Darwin Harbour has the potential todischarge 48,000m3 of ballast water. Phillips may wish to contribute tomaintaining the rigorous exotic pests program currently conducted forDarwin Harbour.

� Impacts of installation of the pipeline may result in alienation ofrecreational, indigenous and commercial fishing activities.

� Impacts of high intensity sound and continuous noise activity may beresponsible for reduced catch rates.

� Concerns regarding impacts of increased turbidity on marine species,their prey, habitat requirements and feeding patterns.

� Issue of restrictions of pipeline corridor on anchoring for recreationalfishers.

NTGOVERNMENT

� PER contains only limited analysis of the significantly increased roadtraffic generated by construction and operation of the facility.

� Assessment of hazardous goods transported is warranted, especially inrelation to sensitive environments and population centres, whichmaterials will traverse.

� Public risk from transportation of hazardous goods should be assessed.

NTGOVERNMENT

� In light of the NT Government’s plan to construct an access road, thecontinued requirement for a construction dock is queried.

� The hydrodynamic modelling of Darwin Harbour conducted for theoriginal proposal in 1997 should be revised to incorporate updates of theDarwin Harbour model.

� Recommendation that a Erosion and Sediment Control Plan be preparedand submitted to DIPE Natural Resources Division for approval.

� Recommendation that the land at the western end of Wickham Point berezoned open conservation. In addition, ensure that the coastal buffer ofat least 50m along the shoreline on the landward or eastern side of thedevelopment and down both sides of Wickham Point be protected.

� Site disturbance has the potential to expose acid sulphate soils. It isrecommended that a geotechnical investigation and analytical testing ofproposed disturbance sites to identify any potential for acid leachategeneration be conducted. Investigations will assist with development ofshort and longer term management strategies to mitigate the impacts ofacid sulfate soils.

� If potential acid sulfate soils are encountered, a management planshould be prepared in conjunction with the DIPE. The plan shouldinclude treatment options and monitoring regime to permit earlydetection of acid leachate on site.

� Caution to be exercised during construction phase with regard toexposure of potentially acid sulfate soils.

� Disturbance of mangroves to remain within designated areas.� Geo-technical advice to be sought, regarding placement of fill material

over in-situ vegetation because of potential for land subsidence.� Mangroves not salvaged should be removed from site and taken to a

green waste disposal site. Disposal offsite will reduce potential breedinghabitats for biting insects on-site.

� Revision of mangrove monitoring programs, committed to in 1998EMP, is required to reflect changes in knowledge and experience withregard to mangrove monitoring. Revisions should be made with specificreference to mangroves in Darwin Harbour.

� Mangrove monitoring program to be prepared in conjunction with DIPE(Natural Resources Division).

� Conservation of the remnant parcel of land at the tip of Wickham Point.

APPENDIX 3


May 2002

58

NTGOVERNMENT

� PER does not indicate location or operation of wastewater reuse area.This discussion should include mechanisms by which disposal is to beachieved and how treated effluent reuse will comply with DHCSrequirements and NWQMS guidelines.

� Stormwater drainage construction for operational phase to be designedto minimise scour velocities in high volume flows.

� Construction phase stormwater management to reference local adviceand guidelines for erosion and sediment control.

� More research is required to characterise material that is to be dredged,including development of a decision matrix to assist with assessingdisposal options for dredge spoil.

� Use of seawater as primary fluid for hydrotest. Use of potable waterconsidered to be a waste of resource and expensive. Seawater should beutilised if there is no undue risk of corrosion or other detrimentalimpacts on facility infrastructure.

NTGOVERNMENT

� Wastewater discharge not adequately defined in terms of potentialvolumes. Further discussion is required in minimising source watercross contamination to reduce potential volumes requiring treatment.Options may include separation of wastewater streams.

� Reuse of treated sewage effluent requires discussion including volumeof holding tanks, location and substrate over which the irrigation waterwill be sprayed and any impact this will have on the stormwater runoffpath.

� Proponent needs to consider other waste disposal options and treatmentmeasures rather than rely on Shoal Bay as a disposal option, especiallywhen some of the wastes generated are inappropriate for disposal at thefacility.

� More detail required for reuse of dredge spoil.� More detail required for proposed recycling facility of building

materials including, will the facility be on site, the basis for deciding thevalue and reuse of materials and contingency to control unrestricteddisposal by contractors.

� Disposal of sludges, alternative methods of treatment and capacity oflocal landfills to accept sludges requires further consideration. Inaddition, alternative methods should be presented for disposal/reuse ofceramic balls, cellulose and molecular sieves where disposal to landfillis inappropriate.

� What alternative options for waste oil disposal are available ifMataranka Lime Kilns were to cease accepting waste oil due toavailability of cheaper fuel source (potentially LNG). Does Phillipshave the capacity to stockpile waste oil in Darwin?

� The impacts of construction noise should be considered and mitigationmeasures undertaken if required. Due to temporal and physicalcharacteristics of the adjacent environment, modelling of noise contoursis suggested.

� Fuel storage on site should comply with AS 1940-1993.� The PER does not provide enough detailed information about waste

management and minimisation options for various waste streams,including any contingency planning in the event of market variation indisposal options.

NTGOVERNMENT

� There appears to be no reference to tidal surge at Wickham Point in theevent of a cyclone. Parts of Wickham Point would be subject to tidalsurge and may affect the LNG plant; this point should be addressed.

NTGOVERNMENT

� Current land zoning at Wickham point is Future Use. The designation ofthe plants operation is best defined as “Offensive or HazardousIndustry” and would need rezoning under the Litchfield Area Plan 1992.The proposed Litchfield Planning Concepts and Land Use Objectivesidentify this area as having future industrial potential. DIPE willundertake to rezone the land to reflect this intention.

APPENDIX 3


May 2002

59

� Consent for vegetation clearance not required because less than 50% ofthe total lot size is proposed for clearance, in accordance with clause22.5 Removal of Native Vegetation

� Developer to be made responsible for control of biting insects, inaccordance with Department of Health and Community Servicesrecommendations.

� Appropriate clearances from the Aboriginal Areas Protection Authorityand Heritage Conservation Services (of OEH) should be sought prior todisturbance of any archaeological sites.

� No indication given in the report to the force of destructive winds andheavy rainfall associated with cyclonic activities. Heavy rainfallassociated with cyclonic activity may make the connector road fromChannel Island to Wickham Point impassable. The developer shouldtherefore construct cyclone shelters on-site.

� Soil types, characteristics and potential for acid leachate generationhave not been adequately described in the PER. Additional sampling toidentify acid sulfate soils should be conducted, especially with referenceto acid leachate weakening concrete structures. If investigationsidentify a problem, management strategies will need to be developed.

� Litchfield Shire Seasonally Waterlogged Soils Map identifies that aconsiderable percentage of the site is subject to severe waterlogging orinundation for extended periods.

� Fill not required on site, as there is an excess resulting from site cuttingvolumes. Excess fill maybe sold to local market or provided togovernment.

� Side-casting into the harbour should be avoided.� Section 4.3.9 (Dredging Spoil and Disposal Impacts) does not identify

disposal options for dredged material. This is of particular relevance ifdisposal may impact coral communities adjacent Channel Island.

� Additional information including details on the location of the effluenttreatment system, management and disposal of dredge spoils, potentialacid sulphate soils management and adequate cyclone shelters should beincorporated into the PER.

� Ongoing management, monitoring and operation of the plant could bedetailed in the EMP.

NTGOVERNMENT

� Proposed greenhouse offsets require careful consideration asarrangements for this proposal may set precedents for future projectsand possible expansions.

� Land is within the draft lease boundaries developed in 1999, has NativeTitle clearance and there is no impediment to proceeding with therevised offer and lease taking into account the proposed variations.

NTGOVERNMENT

� Land zoned under Future Uses in Litchfield Area Plan 1992 and willrequire rezoning and development consent to facilitate the planneddevelopment.

� Rezoning is intended during finalisation of the Litchfield PlanningConcepts and Land Use Objectives and consequential amendments tothe Litchfield Area Plan.

NTGOVERNMENT

� Greatest potential for creation of new mosquito breeding sites will arisefrom disturbances by construction activities in or near tidal areas.

� Construction companies are urged to adhere to specific guidelines(Construction Practice Near Tidal Areas In the Northern Territory-Guidelines To Prevent Mosquito Breeding, Whelan 1988)

� Drains to be of concrete construction and be designed to ensure flowwill continue despite relatively small volumes (e.g. dry season).

� Drains to discharge to suitable endpoints. Each endpoint should haveerosion protection to prevent creation of a plunge pool.

APPENDIX 3


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60

� Silt traps to be constructed at all silt entry points and to require aminimum of maintenance. Silt traps to contain low flow inserts.

� Rectification of mosquito breeding sites by draining or filling potentialbreeding sites as discussed in Section 4.4 of Biting Insects of MedicalImportance at Wickham Point, Darwin Harbour.

� Sprinkler dispersal of treated sewage should conform to National Healthand Medical Research Council Guidelines for Reuse of Wastewater.Sprinkler to be moved once a week to prevent waterlogging of groundnear sprinkler heads.

� Siting of any high use personnel areas, particularly those used in themorning and evening, should be in the southwest section of the island tominimise contact with Culicoides ornatus.

� Advisable that all personnel are provided with information aboutpersonal protection from mosquitoes and biting midges. In this regardthe DHCS has produced a publication “Personal Protection fromMosquitos and Biting Midges in the NT 1997”.

� With a maximum workforce during construction of 1600 it is unlikelythat portable toilets will be sufficient to treat sanitary waste. May needmore permanent facilities installed.

� PER does not provide anticipated effluent criteria for the process waterand potentially contaminated storm water nor treatment thresholds.

� Treatment and Disposal of wastewater will need to comply with the SiteSpecific Type Approval by the DHCS.

� Treatment and disposal systems must comply with the Code of Practicefor Small On Site Sewerage and Sullage Treatment Systems and theDisposal and Reuse of Sewage Effluent.

� The proponent should discuss Naturally Occurring RadioactiveMaterials (NORM’s), especially if disposal is required, and anyassociated requirement for protection for on-site personnel. In addition,will any radioactive sources or irradiating materials be used for thepurposes of operating the plant? If so, operations will need to complywith the respective provisions of the Radiation (Safety Control) Act.

NTGOVERNMENT

� Consider the acquisition of dry rainforest area for conservation purposesappropriate; however a requirement to identify area of dry rainforest tobe protected and who will pay. Details of proposal are important due toincreased size of area to be cleared.

� Recommendation that Phillips pay for dry rainforest acquired andcontribute financially to fencing and management.

� Dry rainforest area to be protected should be much larger than the areacleared for construction of the plant. If a precedent is set then thismeasure will ensure that the majority of dry rainforest in the region willbe conserved.

� Protection and management should be viewed as improving an area’secological integrity by for example 10%. In this case the area protectedcould be ten times the area destroyed, which has had a100% reductionin ecological integrity.

� Protection of surrounding ecosystems is integral to conserving an areaof dry rainforest due to the reliance of fauna and flora on externalhabitats for foraging; therefore, the area conserved must be larger thatthe area which will be cleared.

� Wildlife corridor presented in the original EIS is not present in the newproposal, and it is not considered that this loss can be mitigated. Theloss of the corridor adds further weight to reach an agreement onprotecting rainforest patches and associated surroundings.

� Disposal of 11 cubic metres of water per day is noted. Surrounding dryrainforest should not be irrigated with this water. Doing so might leadto a loss of ecological integrity.

APPENDIX 3


May 2002

61

NTGOVERNMENT

� Proponent to make clear where and how fauna corridors will operate.� Greenhouse offsets in the PER are far from clear. Greenhouse offsets

should be resolved and commitments made prior to the plant being putinto operation.

� Statement on threatened species incorrect. Three species of IUCN listedvulnerable seahorses have not been investigated.

� Three seahorse species in the harbour are considered vulnerable byIUCN. One of theses species appears to be dependent on mangrove androck mangrove habitats.

� Thirteen species of fish found in Darwin harbour, including the threespecies of seahorse, were listed as threatened in a report prepared by theNSW Fisheries Research Institute and the Australian Museum. Aconservation overview has been submitted to Environment Australia,which is still processing the submission.

� Coral communities identified in plate 8 exist close to each end of thebridge not just at the place identified.

� Predicted emissions appear to be close to “ambient standards”(especially NO2 levels) and would not take much to exceed thosethresholds, ie in a worst case scenario. Air dispersion modellingindicates significant levels close to ambient levels of NOx will occurover the Darwin CBD and northern suburbs. The PER does not discussacid rain or the long term environmental and health exposure to thesepollutants.

� Greenhouse gases from the expanded LNG plant are considerable. Theproponent does not state how exactly they are going to compensate forthis. This issue must be resolved.

� LNG releases have the potential to reach and affect occupied buildingsand perhaps the proposed new highway. In Appendix G (p 23) it isstated “that these potential situations will be reviewed as the projectprogresses” The department considers that this should be have beenreviewed in the PER.

� The risk assessment does not deal with catastrophic environmentalinfluences, i.e. lightning strikes. It is suggested that maps be providedshowing the effects of worst case scenario (catastrophic) incidents at theplant.

� Risk assessment issues of proximity of the LNG plant to the CBD andother future developments, during the life of the plant, should have beenclearly spelt out in a non-technical way in the PER.

NTGOVERNMENT

� Use of vapour recovery equipment is supported, as it will lower thecumulative impact of emissions in the Darwin airshed.

� Discharges of treated effluent and potential contaminated stormwaterand the cumulative impacts on Darwin Harbour should be considered,especially impacts on nearby aquaculture projects and PAWAdischarges from waste water treatment plants. Proponent should checkwith DIPE (Natural Resources Division) on the hydrodynamicsinvolved.

� It should be acknowledged that emission levels from the Channel Islandpower station are generally low and have no detrimental effect onregional air quality.

� PAWA is satisfied that ground level NOx concentrations arising fromthe operation of Channel Island and the LNG plant will not impactregional air quality.

� Any proposals to significantly increase NOx emissions from anyupgrade or expansion of the LNG plant should be referred to PAWA forcomment.

APPENDIX 3


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NTGOVERNMENT

� Phillips should provide the NT Government copies of environmentalperformance reports for its plant at Kenai and for the Atlantic LNGplant (with Phillips technology but run by another energy company) inTrinidad. In particular, the frequency and extent of incidents withsafety or environmental risks (e.g. gas leaks, oil spills at plant or fromcargo ships, explosions, etc.).

� How does Phillips plan to treat and/or dispose of mercury stripped fromthe natural gas? Phillips should include this in their EnvironmentalManagement Program (e.g. Waste Management Plan).

� Why is only 25% of the construction workforce to come from Darwin?� Which standards or specifications will apply to fuel storage to ensure

that bunds will fully contain the largest possible spill and that sumps areappropriately located?

� Because of the risk of generating extensive and/or persistent sedimentplumes, side-casting would be permitted only if Phillips coulddemonstrate (e.g. by seabed sediment analysis and hydrodynamicmodelling) that material would be coarse enough to settle out quickly,e.g. gravel, rubble, coarse sand. Also, as part of the EMP, Phillips willhave to produce a Dredging and Dredge Spoil Management Plan forapproval by DIPE.

� Darwin is subject to 2-3 “Cyclone Watches” each wet season; therefore,Phillips needs to specify the risks and responses to these annual events,especially in terms of shutdowns and safeguards.

� Phillips will need to obtain a Waste Discharge Licence to dischargetreated effluent to Darwin Harbour.

� If a vessel is required to leave the loading dock when cyclonic winds areanticipated, where will the vessel go? Are there safe havens in theHarbour or will they be forced to put to sea? The risk of groundingsand collisions must be avoided to prevent an oil spill in the Harbour, asmangrove forests are particularly vulnerable to damage from spills (i.e.hard to protect, easy to kill and nearly impossible to clean andrehabilitate). Phillips will need to provide answers to the abovequestions in its Emergency Response Plan(s).

� The paragraph under Sec 4.2.1 indicates that the “total area of landdisturbed would increase from 66.8 ha to 100 ha; however, the first dotpoint in the 2nd par of Sec 4.2.2 indicates that the increase of “grounddisturbance” would be 88.3 ha. Phillips needs to confirm the actualamount of disturbance to build the 10 MTPA plant.

� The PER indicates that H2S from amine unit will be burned to produce80.6 kg/hr SO2; however, Table 4.2 reports total annual emissions at130 MTPA. These differing units make it hard for the reader todetermine the significance of this source to the total annual SO2 output.

� The PER indicates that various vapour and heat recovery technologieswill reduce emissions; however, Phillips does not specify the actualreduction in volumes, except for NOx. Also, will emissions remain lessthan NEPM limits during the dry season with its substantialcontributions of particulates from bushfires?

� The PER does not discuss the generation or mitigation of odours. Ifodours will not be generated, then this needs to be stated explicitly. Ifthere are odours to on-site personnel only or to people off-site (e.g. ifstrong winds blowing from the plant to the CBD occur), Phillips needsto discuss this potential impact and its mitigation.

� Phillips will discharge clean stormwater from the clean parts of the sitevia drains into the “intertidal zone at selected points adjacent to thesite”; however, the nature of the substrata at these sites is not specified.The risk of erosion needs to be addressed; ie the potential will be greaterif water is discharged onto exposed sand- or mud flats vs. mangroveforest.

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� The proposed figure for discharge of hydrotest water is 90,000 to100,000 m3; however, the combined volume of the LNG storage tanksalone is 360,000 m3 and doesn’t include other storage tanks (eg.condensate). Does this mean that the tanks need not be filled to testtheir integrity? Phillips needs to describe the likely toxicity andpersistence of the chemical additives to the hydrotest water and discussother options to direct disposal (eg. treatment, transport off-site, etc.).

� Phillips needs to include impacts of detonations (to level portions of thesite not amenable to earthmovers) on noise levels.

� Phillips indicates that during upset and emergency operating conditions,the “noise levels…will tend to be higher than … for normal operatingconditions; however, these sources will be of short duration and veryinfrequent.” Phillips needs to provide a more quantitative indication ofthe increase, duration and frequency.

� Phillips also indicates that flares will not present undue risk to local airtraffic; however, more information is needed for the reader to judge thenature and extent of this risk and any proposed mitigation. Further, thePER mentions ground and marine flares, wet and dry flares butbackground information is not adequate for the reader to understand thedifferences and how wet and dry flares relate to the ground and marineflares.

� Phillips indicates that “the most significant heritage site on WickhamPoint (MA17) will not be disturbed by construction activities”;however, Figures 3.11 and 3.12 show the road/bridge from the futureman-made Goyder Island running straight through this area.

� As indicated in the NT’s PER Guidelines (p 5), Phillips needs toconfirm that the boundaries of the 10 MTPA plant conform to theAuthority Certificate previously issued by AAPA to Phillips or obtain anew or revised Certificate to cover the new “footprint.”

� Phillips needs to ensure the efficiency and effectiveness of itsimmediate response to an oil spill by frequent drills (wherein responsepersonnel access and assemble response equipment, initiatecommunication and reporting networks, etc.) and desk-top exercises.

NTGOVERNMENT

� The NT Government and Phillips have been consulting on work healthrequirements. These were essentially notifications of work andsubmission to the department of appropriate safety plans/cases. Inaddition, discussion was undertaken identifying the requirements forcompliance with the National Code of Practice for Major HazardFacilities.

NTGOVERNMENT

� The PER indicates that there are no tidal constraints for vessels up to11.5m in draft; this is not correct. Minor high points in the accesschannel require removal. The additional dredging can be undertakenusing the same equipment and environmental controls for dredgingactivity associated with the construction dock.

� Restriction in the access channel would be experienced at Charles PointPatches presently 12.2 m at low water.

� Berthing and departure procedures for LNG carriers will requireverification for all tide and wind states. Verification will establish anyrestrictions that will apply to vessel navigation.

� The final EMP should be updated to reflect the present status of EastArm Port and future development plans.

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NORTHERNLAND COUNCIL

� No characterisation of contaminants likely to be present in hydrotestwater.

� No characterisation of the process water or the proposed treatmentsystem for that water. Without these data, the proposal to dispose oftreated process water by irrigation cannot be adequately assessed.

� Inadequate description of solid and semi-solid waste disposal.Contractors should be bound by conditions specified in the final EMP.

� Clearing of dry rainforest should be staged to avoid unnecessaryremoval of this significant habitat (if portions of this habitat can remainwithin the disturbance footprint). Flares should be sited elsewhere topreserve areas of dry rainforest.

� Local ecosystems (including vegetation in non-populated areas south ofDarwin) could be adversely affected by “acid rain.” Modelling shouldhave included variables for humidity and precipitation.

� Sulphur removal from the flare gas should be presented on acost/benefit basis on available technology.

� No predictive modelling was presented for long term ecological impact,e.g. insufficient characterisation of wastewater; therefore, cannot assessimpact on biota and ecosystems in the long term.

� Predictive modelling of airborne contaminants over the life of the plantis not possible without the inclusion of humidity and precipitation data.

� The proponent should have sufficient data, based on its other plants, toprovide estimates of contaminant accumulation or ecologicaldegradation over time.

� The EMP included in the PER is insufficient in detail to be assessed atthis stage. The NLC would appreciate the opportunity to be involved inplanning, preparation and on-going approval of the EMP.

� As the 9 MTPA plant was not approved, it is inappropriate to use it forcomparisons to the 3 and 10 MTPA plants in the PER.

� Given the daily emission rates (water, air), it is difficult to accept theassertion that it will be a “clean” plant.

� It is uncertain if the second train will be constructed. The implication isthat approval of this proposal would result in a greater degree ofdisturbance than might be necessary for a 5 MTPA plant.

� Use of this area by local fishermen (indigenous or otherwise) is nothighlighted in the PER. The risk exists to the local fishery and to thesafety of consuming the local catch.

� On the basis of information in the PER, there are no means to assess theproject in terms of royalties and other payments to the Commonwealth.

� It is uncertain whether industrial benefits from the project will flowthrough to the Northern Territory, especially if no other fields areaccessible to the proponent.

� The proponent is willing to participate in an Australian venture toadvance the use of mallee oil and wood as fuel for power generation,and the support of such a significant “player” has the potential to kick-start the nascent industry. The consultants engaged to do this portion ofthe PER have provided a very good document on current alternatives.

� The employment opportunities presented by the proponent arewelcomed within the NT economy, which otherwise rests on a poorskills resource base.

� The contribution to the three economies (local, Territory and national)is welcome and undeniable, although not detailed in the PER.

� The redesign of the on-site flare into a ground level system hasadvantages and disadvantages, the main disadvantage being theincreased area of disturbance arising from such an arrangement. Thereis a need to balance aesthetic, environmental and risk considerations.

� The relocation of most of the LPG liquefaction to offshore removes apotential source of contamination from the onshore facility and shouldbe seen as a positive move as long as the process is well managedoffshore.

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GERRY WOODMLA

(MEMBER FORNELSON)

� CO2 emissions: Phillips shows a figure of 18,000 tonnes/day. Whatare the actual offsets or gains that can be shown in reducing thisamount in a global context?

� Industrial pollution: What controls are in place to stop generalindustrial pollution into the Harbour, e.g. oils?

� Rock groyne: Will the rock groyne used as part of the jettyconstruction cause a change in currents that may cause other effects?Could pipes be placed through the groyne to allow for some movementof water under that part of the jetty?

� Peak Hill removal: Will removal of part of Peak hill for fill mean thatthe LNG tanks will be more visible because part of the hill will havebeen removed?

� Future expansion: Is there any intention to use any of the land outsidethe site boundary for future expansion of the project?

� Zoning: Why does Figure 3.11 show a portion of Section 1860 takingover all of Peak Hill and including a right of way to the jetty andmangroves? Section 1860 should include the site only. The rest of theland should be Crown Land, zoned OC (Open Conservation). Thepublic should have some access to the area and Peak Hill may allowsome future opportunities for that to occur, e.g. viewing from themiddle of Darwin Harbour (limited tourism).

� Effect on air traffic: What effect will the plant have on Darwin Airportand the approaches?

� Light pollution: Will there be any controls to reduce light pollutionemanating from the site, so that the night sky is affected as little aspossible?

ENVIRONMENTCENTRE NT

(KIRSTENBLAIR & MARKWAKEHAM)

� Major industrial development, of which this facility is just the firstexample, is not compatible with the significant ecological values ofDarwin Harbour.

� The PER does not provide adequate information about the impact ofhabitat loss on federally listed migratory species, such as the MelvilleCicadabird and the White-Bellied Sea Eagle.

� The impact of this development on dugongs, green turtles andhawksbill turtles is not adequately addressed.

� With no clear information about the lifespan of either the constructionor operational phases, it is impossible to estimate the total waterrequirement of this proposal.

� There is insufficient information about the contaminant levels in thehydrotest water, proposed for discharge into Darwin Harbour.

� Passing reference is made to the fact that this development is proposedwithin an area of high cyclonic activity. It is suggested the potential forcyclones (including wind-loading) be considered in the design of thefacility.

� There is no mention of mitigating any storm surge that may beassociated with a cyclone, particularly if this occurred in conjunctionwith a high tide.

� The PER states that “the use of LNG and natural gas as a preferred fuelfor existing and new facilities, in place of alternative fossil fuels, willreduce global greenhouse emissions in accordance with the objectivesof the Kyoto Protocol.” No evidence is, however, provided.

� The “no-regrets” measures are made contingent upon the “terms of anyLNG sales and feed gas purchase agreements that are eventuallyexecuted.” This is clearly not commitment enough.

� Phillips does not appear to have explored in the PER all the potentialmitigation options that may be available, e.g. steam turbines, flash gas,

� Phillips does not appear to have explored whether it is possible tosubstantially reduce the emissions from the acid gas removal process.

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� The ECNT does not consider the offsetting of emissions throughvegetative sinks (such as mallee plantation) to be a particularly usefulapproach. First and foremost, emissions need to be reduced at thesource.

ROB WESLEY-SMITH

� Now that Phillips has approval for a 3 MTPA plant at Wickham Point,it is now relatively easier to expand this to 10 MTPA. This was nodoubt a tactic.

� Vastly more acceptable to the people of Darwin if the plant had notbeen located in the middle of the Harbour, a few km upwind of theCBD.

� Phillips previous management used various pressure tactics to get theEast Timor Government and the community to quickly approve theproject and the LNG plant

� Phillips downplays the ability of hardwood forests in the NT toameliorate the carbon releases. Doing this locally should not bedismissed out of hand. On Wickham Point some plantings may be agood end use for excess freshwater and may be used to soften theoutline of the plant.

� The Los Palos area of East Timor would be a good area, subject to localwishes, for a large reforestation project.

� CO2 at 10 MTPA is to be released at 5 MTPA. This and othergreenhouse gas emissions are too high. Since there is quite a bit of CO2in the gas from Bayu-Undan, best practice would be to ensure that it isextracted at the wellhead and pumped back into an undergroundreservoir.

� Released gases will have a maximum concentration over the CBD,which is not acceptable.

� CO2 on a warm plume will attract insects, which will attract birds andpose a big hazard to aircraft.

� Details were insufficient on the treatment and safe disposal of gasesand oil sludge.

� Some feel-good projects could be for Phillips to operate only newtechnology ‘green cars,’ to support solar and wind/tide researchprograms, even to subsidise solar panels in East Timor and remote NT.

� More positive noise barriers/diversions need to be in place.� Dredging will create lots of sediment that could smother local reefs.� The greatest danger will come from 200 ship movements per year a few

hundred metres from the Navy Base breakwater and point atLarrakeyah, and the consequences of coming upon the rocks. Maybe abuffer barrier should be built around this area.

� Phillips could facilitate ensuring that the MoA does not jeopardise EastTimor’s rightful maritime boundaries.

THE PLANNINGACTIONNETWORK(PLAN)

(MARGARETCLINCH)

� The proposed LNG plant on Wickham Point is incompatible withtourism, and its impact would far outlive the life of the plant as well asreducing the Darwin airport’s operational capability.

� A highly visible petrochemical plant will raise alarm and a lastingimpression that may well counter our tourism profile in the future. Theoperations of fishing charters will be restricted (because of exclusionzones).

� Phillips’ previous management used various pressure tactics to get theEast Timor Government and the community to quickly approve theproject and the LNG plant.

� The omission of detail regarding the issues surrounding flight paths andthe location of the LNG plant needs to be rectified and made public.No risk analysis of the impact of the LNG plant on aircraft operationswas done. If alterations occur to flight paths, this could then displaceaircraft over more populated areas.

� Phillips is negotiating with CASA to increase flight path height, whichwill increase aircraft operational risk (from reduced visibility).

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� Lightning effects have not been considered in the report.� It is assumed that lightning arresters will be installed; therefore, the

strike intensity will only increase and this will increase the risk toaviation.

� The EIS and PER do not study the impact of the production flares andfull-time lighting on insect communities and higher trophic levels.

� Litchfield Land Use Objectives promote most of the Ware peninsularegion as an industrial area. Assessment for this area was lacking inscope, especially aviation.

� The EIS and PER fail to adequately assess the risks of chemicals otherthan LNG.

� Phillips put forward the necessity for a 3 km buffer zone. This does notequate with the current proposed Section 1860 and 1861.

� LNG and natural gas have the same general properties, i.e. are anasphyxiation hazard and can, “in the absence of an ignition source,result in a plume that could migrate downwind for a considerabledistance.”

� Phillips will be removing Aboriginal archaeological remnants and alsoWWII ruins. The historical context will be lost for these sites. Wouldthis be the case if the LNG plant were in the Glyde Point region?

� That the pipeline route into the Harbour is within metres of bothAmerican and Australian War Graves is alarming.

� This particular area is subject to seismic effects, as illustrated by arecent NT News article, dated 17 April 2001.

� Australia was recently reported to be already 33% above the KyotoProtocol in terms of GHG. The target for GHG was meant to be 8%.This shows a need for caution.

� Modelling done for emissions was done with data from Darwin airport.Data from Channel Island monitoring stations show that wind strengthsand directions are noticeably different. These differences need to bemodelled.

SCOTTWHITING

� The potential disturbance to dugongs and turtles in the vicinity ofChannel Island cannot be dismissed as easily as saying that theconstruction and operation of the LNG shipping and port is 4 km away.Increased boat traffic and noise can displace the local population.

� Preliminary data on dugong movements in the Darwin Region will beavailable in the near future.

� No reference is supplied for statement “Seagrasses in Darwin Harbourare known to occur off Mandorah, and between Channel Island and themainland.”

� Flatback turtle has been listed with the wrong species name (on p 3-20);the correct name is Natator depressus.

� The bottlenose dolphin also occurs in the Harbour.� The comment that a ‘dugong and turtle habitat project currently

underway will provide definitive mapping of favourable habitats withinthe Harbour’ is misleading – the project will add data on distribution ofdugongs, habitat use and movements, and will not be “definitive.”

� Important reefs and intertidal areas around Channel Island are notshown on the map.

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R.L.K.WHEELER

� To have a project of this nature handling an extremely volatile liquidproduct, less than 5 km to the Darwin CBD is frightening.

� Having the facility located at Glyde Point would appear to effectivelyremove the risks and many of the problems with Darwin Harbouroption has.

� Areas of concern are the methanol manufacturing and oiledpetrochemical manufacturers who inevitably will follow and be locatedadjacent to the LNG project.

� How safe is the pipeline that is to run into and down the Harbour?� What about ships at anchor, dragging anchors in storms. Will the

pipeline be buried to avoid snagging anchors or anchor damage to thepipeline?

� How many ships will use the Harbour and what size will they be?� Has any consideration been made regarding the grounding of an LNG

tanker on the reefs external to the Harbour?� Have various environmental issues been fully and independently

assessed and honestly addressed?� Have disaster plans been considered? Will training, hospitals and

emergency services be capable of handling a possible disaster?� Who will foot the bill if such a disaster occurs.� What responsibility will multi-nationals really accept for damage if it is

incurred?� Will the companies concerned be footing the bill for removal and

restoration of the land and Harbour disturbed by their operation?� Closeness and implications of defence establishments and effects on

aviation.� Effects on the environment from wastewater used for irrigation.� What measures will be used to ensure the environmental health and

safety issues are fully complied with, including OH&S matters foremployees?

� Is Darwin to become just another ugly, polluted and congestedindustrial city on the edge of a cesspool of a Harbour for the sake ofprogress and the almighty dollar?

JEFF BUTLER � If all gas from Bayu-Undan will be processed for export to Japan,where will Phillips be accessing fuel to run the plant at WickhamPoint? Note: gas reserves from Mereenie and Palm Valley will run outover the next few years, so this source will not be available.

� Although Phillips indicates that the increase in greenhouse emissionsfrom the expanded facility will be somewhat offset in a global sense byuse in Japan rather than coal, diesel, etc., the NT will not directlybenefit, and, in fact, will lose greenhouse “credits” because of Phillips’emissions. Can Phillips demonstrate offsets that are of direct benefit tothe NT?

� The plant will be producing 12 m3/day of wastewater and, at the publicforum, Phillips indicated that ALL of this would be treated forirrigation. What will be irrigated, and how will Phillips deal withtreating the different types of wastewater (considering that the differentstreams will have different types and quantities of contaminants)?Does Phillips recognise that their proposal will require a significantlevel of staffing to achieve its proposed plan?

� Considering the wind direction during the dry season and “build-up” (tothe wet season) will flow from the proposed Phillips site across toDarwin, or at times to Palmerston, to what extent will odours from theplant be discernable to residents at these locations?

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THE SAVEDARWINHARBOURGROUP

(DUNCAN DEAN)

� The proposal by Phillips to build a 10 MTPA LNG plant on WickhamPoint, opposite the CBD in Darwin Harbour, rather than at Glyde pointon the Gunn Peninsula is a serious threat for the people of Darwin.

� Large quantities of treated effluent from the plant would be irrigatedonto the land surrounding the plant with excess effluent running off orbeing pumped into Darwin Harbour.

� Discharges to the Harbour threaten the marine biota.� Occasional flares will occur at the plant and this could dramatically

increase the amount of pollutants released.� The flares pose a risk to aviation, either directly or by entraining insects

and thus birds.� If current flight paths are diverted, aircraft noise will impact the public.� The project would seriously detract from the Territory’s outback image.� The plant would generate industrial lighting pollution.� A cyclone could cause a catastrophic incident at the plant.� The plant would increase the risk of terrorist attack on Darwin.� The project would put additional strain on the water supply.

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ENVIRONMENTAL COMMITMENTS AND SAFEGUARDS

The following table summarises environmental commitments made by the proponent and additional safeguards arising from review of the PER. Thecommitments/safeguards have been taken from the PER; from the proponent’s Response to Submissions (from the NT Government and the public); from thecurrent Environmental Assessment Report (No. 39); and from the previous Assessment Report in 1998 (No. 24, for the EIS for the 3 MTPA LNG facility).

NOTE: Table 5.1 in the PER presents a similar summary of the proponent’s environmental management commitments and safeguards. In developing thefinal EMP for the 10 MTPA facility, the proponent should refer to both documents and consult with relevant NT Government agencies to reconcilevariations in approaches between these two summary tables.

PAGE REFERENCESCOMMITMENT/

SAFEGUARDPER

Proponent’sResponse toSubmissions

AssessmentReport

39

AssessmentReport

24

RECOMMENDATIONfrom Assess’t Report 39

[Recommendation fromAssess’t Report 24]

PLANNING & FUTURE EXPANSIONProponent will liaise with DIPE regarding future management of northern tipof Wickham Point (Section 1861).

19, 35 11

Any proposed expansion beyond the 10 MTPA plant or changes tooperations that substantially increase emissions (especially NOx) will requirefurther assessment under the NT Environmental Assessment Act.

48 12, 14 11, 12 2 [3]

ATMOSPHERIC EMISSIONSProponent will quantify major emission sources during commissioning, byemission testing programs; if required, monitoring will be done for NOx toensure compliance with NEPM standards; procedures will be developed inconsultation with OEH.

4-5, 5-3 20, 43 13 28, 29 3 [13]

Acid gas incinerator, management of wastes by professional contractors andother measures will prevent production of off-site odours.

21, 22, 62 16

To further reduce atmospheric emissions and ensure that the bestenvironmental and economic choices are made, the proponent will continueto evaluate alternative turbine combustion technology during the designphase of the project.

4-5

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COMMITMENT/SAFEGUARD PER RESPONSE E.A.R. 39 E.A.R. 24 RECOMMENDATION

GREENHOUSE GAS EMISSIONSThe project will incorporate a waste heat recovery system from the gasturbine exhaust and use it for various heating requirements. (This willmitigate the release of greenhouse gas emissions that would have beenreleased if gas fired equipment were used to provide the same heatingrequirements.)

4-12

A ship vapour recovery system will be used to minimise or eliminate flaringof gas generated during LNG tanker loading and resulting in greenhouse gasemissions.

4-13

During design and construction phases, proponent will continue to evaluateoffset options, including vegetation-related offsets and geologicalsequestration (= reinjection offshore) and options for reducing greenhousegas emissions.

4-12 to 4-17 24, 47 16 29, 30 4 [14]

Consideration of vegetation-related offsets will include projects in EastTimor and others specifically of benefit to the Northern Territory. For thelatter, the proponent will work with the Greenhouse Unit of the NT OEH.

24, 50, 52 17 29, 30

The EMP will contain a specific section on strategies to reduce greenhousegas emissions, including provision for audits, a process of regular review ofnew technologies, benchmarking against other LNG facilities (to achieveinternational best practice), and consideration of offsets.

17 30 4 [14]

The proponent will liaise with the NT OEH in developing its GreenhouseStrategy, and the strategy will be provided to Environment Australia.

17 30 4 [14]

As part of the proponent’s commitment to participate in the CommonwealthGovernment’s Greenhouse Challenge Program, the proponent will develop adetailed Cooperative Agreement with the Australian Greenhouse Officewhich will outline:� An inventory of GHG emissions from the facility;� An action plan to minimise emissions;� Performance indicators to measure progress; and� A forecast of expected abatement of GHG emissions over a set time

period.

4-16

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FLARINGThe proponent will continue to work with consultants, CASA and otherrelevant agencies to identify, quantify and mitigate any impacts to airspacefrom flaring.

4-17, 5-10 8, 48, 54 17 35 5 [16]

TEMPORARY SANITATION FACILITIES (Construction Phase)The proponent, through its main contractor, will establish procedures forcollection and off-site disposal of waste products, and methods will complywith regulations of the DHCS.

5 18

HYDROTEST WATERThe proponent will further consider the option of using sea-water (instead offreshwater) if risks from corrosion can be sufficiently minimised andadequate cleaning tanks prior to commissioning proves feasible.

4-17, 5-3 25 19 6

If hydrotest water will contain toxic additives, the proponent will obtain aWaste Discharge Licence which will require full analysis of the hydrotestwater and environmental monitoring to ensure adequate dilution anddispersion reduce risks to marine biota to an acceptable level. Beforedischarging such hydrotest water, the proponent will provide adequate noticeto nearby aquaculturists to allow time to implement desired precautionarymeasures.

4, 26, 43 19

IRRIGATION WITH WASTEWATER & STORMWATERTo minimise discharge of wastewater and stormwater to the Harbour, theproponent will treat this water and use it to irrigate vegetation on-site, exceptfor contingent events (such as wet season saturation).

4-17, 5-3 4, 8, 43 19 16, 30

Low volumes of treated sewage will be pumped to a sewage treatment plantand treated effluent will be routed to an irrigation system afterdechlorination. Holding tanks for treated effluent will allow testing toensure the water quality is suitable for irrigation.

4-17

Treatment and disposal by irrigation of all wastewater will comply withrelevant NT and Commonwealth guidelines for re-use of wastewater. Thiswill require to proponent to do detailed site assessments and submit findingsto DHCS for Site Specific Type Approval.

4-17 8, 26, 43 20 17, 30 7 [8]

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The proponent will liaise with DIPE, DHCS and other NT Governmentagencies to design the most environmentally-appropriate irrigation systemfor the site.

4-17 8, 43 20 17, 30 7 [8]

The proponent will evaluate (during the design phase) the feasibility andbenefit of using local hardwoods for landscaping and soaking up wastewaterused for irrigation.

52 20

To avoid impacts on the ecological integrity of surrounding dry rainforest,treated effluent will not be used to irrigate this vegetation.

26 20

DISCHARGE OF WASTEWATER & STORMWATER TO DARWINHARBOURThe proponent has indicated that there will be no point-source discharge ofwastewater to the Harbour from construction activities or temporaryfacilities during the construction phase.

11 39

Uncontaminated stormwater will be segregated from potentiallycontaminated streams and disposed of by direct discharge to adjacent waters.Stormwater collected within the process area will be routed to a drain sumpand oily derivatives removed prior to discharge.

4-17 11, 12 20

Once the design of the wastewater treatment system is completed, theproponent will confirm with DIPE the conditions under which directdischarge to the Harbour may be done (in contingency situations). If suchdischarge is considered a risk to nearby aquaculturists, the proponent willmodel likely trajectories and liaise with these facilities to developcontingency plans to protect their operations. The proponent will need aWaste Discharge Licence to release treated effluent to the Harbour.

8, 11, 12, 43 21 30

POTENTIAL FOR RADIOACTIVE WASTE STREAMSAlthough levels of naturally occurring radioactive materials (NORMs) in thefeed gas will be low, the proponent will comply with all applicable NTregulations and guidelines should there be any radioactive wastes requiringdisposal.

31, 32 21

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DISPOSAL OF SOLID & SEMI-LIQUID WASTESThe proponent will actively pursue waste minimisation and recyclingopportunities to reduce solid and semi-liquid waste streams where possible.An Operational Waste Management Plan, prepared as part of the EMP, willfurther detail the proponent’s approach to managing these wastes.

5-4 43 22 32

Non-hazardous wastes (e.g. ceramic balls, biological sludge and domesticgarbage) will be disposed of by waste management contractors and will meetrequirements of OEH.

4-19

Wastes not suitable for disposal at the Shoal Bay Waste Disposal Site (e.g.waste oils, biological sludge and spent solvents) will be disposed of bycommercial waste management contractors. The proponent will reviewwaste-tracking documentation to ensure these wastes are disposed in amanner approved by OEH.

27 22

CONSTRUCTION WASTESWhere practical, the proponent will use cleared terrestrial vegetation and/ormangroves for rehabilitation. Cleared vegetation will not be stockpiled on-site (to avoid creating breeding habitat for biting insects).

4-18 27, 37 22

Stockpiled vegetation will be burnt only as a last resort (as a disposalmethod).

4-18

To avoid land subsidence, geo-technical advice will be sought if vegetationwill be left in place and covered with fill.

27, 37 22

Removal of domestic wastewater will be contracted to a local wastemanagement company and the proponent will require waste trackingdocumentation to ensure disposal meets the requirements of OEH, DHCSand PAWA.

4-18

Waste oils will be collected and disposed of properly through a commercialwaste management contractor.

4-18

A temporary area will be established for stockpiling scrap metal, which willbe collected for off-site recycling and/or disposal. Construction wastes willnot be disposed of on-site.

28 22

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A full description of the proponent’s plans for management of constructionwastes will be included in the Construction Environmental ManagementPlan (as part of the EMP)

23 26

SPENT AMINEThe plant design will facilitate collection and re-use of amine. If disposal isrequired, the proponent will include options for disposal in its OperationalWaste Management Plan prepared as part of the EMP.

28 23

CARBON BEDS (containing waste mercury)The proponent recognises that carbon beds containing mercury may not besuitable for disposal at any landfill site and will include options for treatmentand disposal in its Operational Waste Management Plan.

28 23

WASTE OIL (Operational Phase)The proponent will liaise with OEH to develop preferred and contingencyplans for management of waste oil.

29 23, 24 8

DREDGING & DISPOSAL OF SPOILThe proponent will develop a Dredge and Spoil Management Plan as part ofits EMP in consultation with the DPC, OEH and DBIRD (Fisheries). ThisPlan will include further characterisation of sea-bed sediments (to refinepredictions about plumes) and a “Reactive Monitoring Program” (to detectand deal with unacceptably high turbidity from dredge-related activities).Monitoring will include ensuring the continued health of coral assemblagesat Channel Island.

5-4 6 24, 25 15 9 [6]

The proponent will need to apply for a Waste Discharge Licence for eitherside-casting spoil directly into the Harbour (if this activity is permitted) ordischarge of decant water from land-based settlement ponds.

6 24 14

To avoid unacceptable cumulative impacts from discharge from bothWickham Point and East Arm Port (if dredging for these coincide) and tofacilitate use of suitable spoil from the LNG project for the Port project, theproponent will liase with the DPC and OEH to coordinate their dredgingschedules and monitoring programs.

5-4 24

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The proponent will liaise with OEH to ensure that dredging works are donein an acceptable manner and that excess dredge material will be managedand disposed of to the satisfaction of OEH.

5-4

The proponent will liaise with nearby aquaculturists to avoid unacceptableimpacts on their operations from plumes generated from dredging activities.

7

SHIPPINGTo minimise the risk of grounding or collision, shipping movements will becoordinated through the DPC, including escort by tugs to and from theloading jetty and with the RAN. A 500 m “moving exclusion zone” aroundeach ship is proposed. The navigational risk associated with shoals ofCharles Point Patches will be addressed by continued liaison between theproponent and the DPC.

4-26 9 26 36

To minimise the potential for direct or indirect disturbance to dugongs offWickham Point, LNG tanker speeds will be kept at an appropriately lowlevel within the Harbour, as agreed with NT Government authorities.

4-28

To minimise risks to dugongs and sea turtles that forage around ChannelIsland, LNG shipping operations will remain away from the Channel Islandarea.

4-28

To minimise potential damage from grounding, collision or other incident,the proponent will prepare, maintain, test and review Emergency ResponsePlans, LNG Accident Response Plans and Oil Spill Contingency Plans(prepared in consultation with the DPC, DIPE [Marine Branch] and otherrelevant NT Government agencies).

5-2 59 26, 27 36, 37 10 [18] & 11 [19]

LNG carriers will be designed, constructed, maintained and operatedin compliance with international standards and subject to regularsurvey and inspection by vessel Classification Societies.

4-25

Recognised international guidelines will be used in the design andconstruction of the LNG jetty and in the establishment of operatingprocedures for ship manoeuvres and cargo transfer.

4-25

APPENDIX 4


May 2002

77


RESTRICTED PUBLIC ACCESSRecreational fishing off the northern tip of Wickham Point will not beaffected by the LNG plant: the only restrictions will be adjacent to theloading jetty and construction dock, both of which are well awayfrom the area of greatest fishing interest. There will be no restrictionof access to landing in the region of the old leprosarium.

4-29

HAZARD & RISK ANALYSISDuring the detailed design phase, the proponent will complete the following:� A final HAZOP (Hazard & Operability) Study, to identify all potential

scenarios involving failure of valves/controls and other upset conditions;� A final QRA (Quantitative Risk Assessment), to identify, assess,

evaluate and manage all potential risks associated with the project; and� A detailed Safety Report for the LNG plant, in accordance with relevant

Worksafe Australia Standards and prepared on the basis of the HAZOPand QRA studies above.

4-24, 5-4, 5-8 40 28 32, 33

All practicable measures to prevent hazardous incidents and to mitigate theirconsequences will be adopted.

4-25

TRANSPORT OF HAZARDOUS MATERIALSThe proponent will do an assessment of hazardous wastes transported to andfrom the facility and prepare contingency plans to deal with any accidentalspillage.

36 29

INCREASED ROAD TRAFFIC (Construction Phase)Use of the road network for transport of materials and equipment will be inkeeping with DIPE regulations and is not expected to have significant impacton commuter traffic.

4-30

Potential road damage from the transport of heavy equipment will beavoided or minimised through use of barges to the construction dock.

4-30

APPENDIX 4


May 2002

78


SAFETY REPORTThe proponent will consult with relevant NT Government agencies (duringthe detailed design phase) during development of a comprehensive SafetyReport that meets the requirements of the National Code of Practice forMajor Hazard Facilities.

4-24, 5-4, 5-8 39, 40 29 33

CLEARING OF VEGETATIONClearing of vegetation will be staged to meet the minimal requirements ofconstructing and operating the plant.

43, 445 30

The proponent’s EMP will include measures aimed specifically atminimising loss and disturbance to remaining dry rainforest and mangrovehabitat at Wickham Point, inlcuding measures to monitor and control weedand feral animal incursions, and measures to minimise fire risks.

4-28 38 30 22 12 [11]

SELECTION OF DRY RAINFOREST OFFSET AREA(S)The proponent will continue to liaise with DIPE to identify an acceptable dryrainforest mitigation strategy, including identification of an appropriate area(size and location).

5-4 38 31

MONITORING OF MANGROVESMonitoring of mangroves adjacent to the facility will be done by theproponent. The proponent will liaise with DIPE and NTU to ensure thatcurrent and appropriate methodology (for the measurement of productivity isused.

5-2 37 31

FAUNA CORRIDORSIf required by DIPE, the proponent will mitigate the potential obstacle theconstruction groyne might pose to faunal movements, by constructing earthramps.

5-4 38 31 24

MARINE BIOTAThe proponent will mitigate risk to marine biota by minimising the dischargeof potential contaminants into the Harbour and by enduring that dischargescomply with relevant guidelines of the National Water Quality ManagementStrategy Guidelines and with all requirements of any Waste DischargeLicences for the project.

11 32 30, 31

APPENDIX 4


May 2002

79


FIRE, WEEDS & FERAL PESTSIn consultation with DIPE, the proponent will produce and implement acomprehensive weed management plan prior to construction of the facility.

4-28 33 32 22, 23

All activities will fully comply with requirements of the Weeds ManagementAct.

33 32

A Site Management Plan will include provisions for� Cleaning and inspection of construction equipment prior to deployment

on site;� Monitoring for introductions (of weeds and feral pests) and their

subsequent removal; and� Fire prevention and control.

4-28

EXOTIC MARINE PESTSAll shipping under control of the proponent will comply with the Australianregulations for the management of ballast water and general AQIS guidelinesto ensure no ballast water exchange occurs within or near Darwin Harbour.

5-7 34 32 32

The proponent will liaise with DBIRD regarding the exotic marine pestsmonitoring program and mitigation of potential impacts from vesselsservicing the facility.

34 32 32

NOISEIn the event that pile-driving is considered necessary, the proponent willmodel potential noise impacts on the residents of Darwin and Palmerston. Iffindings indicate a significant potential for disturbance, a Noise ManagementPlan will be prepared, in consultation with OEH and implemented by theproponent.

29, 30 33

In the unanticipated event that explosives are required (e.g. to prepare sitefor construction), noise reduction measures, such as the use of weightedblankets, will be adopted.

2-10, 4-20 30 33

A detailed modelling study will be done after completion of the design phaseto refine preliminary predictions of noise generation.

4-23

To minimise risk of disturbance to the public, construction work will bedone during daylight hours, when background levels of noise at the nearestpopulated areas will be greatest.

30 33

APPENDIX 4


May 2002

80


The proponent will ensure that noise during construction and operation ofthe plant will be managed to the satisfaction of OEH and comply with theWaste Management and Pollution Control (Environmental Noise)Regulations (when these come into effect).

30 33, 34

BITING INSECTSTo avoid creating mosquito breeding areas, the proponent will comply withthe NT Government’s guidelines “Construction Practice near Tidal Areas inthe Northern Territory – Guidelines to Prevent Mosquito Breeding” (Whelan1988).

5-6 2, 15 34 16, 21

The proponent will prepare a detailed Biting Insects Management Plan tocomply with requirements of the DHCS and to include in the final EMP.

15, 16 34

Personal protection of employees from biting midges will be employed andinduction training implemented to ensure that the problem is managed inaccordance with recommendations by DHCS, and the proponent’s approachwill be detailed in the EMP.

16 34

RADIATIONAlthough the occupational risk from radiation is considered to be low, theproponent will develop procedures for protecting personnel from naturallyoccurring radioactive materials (NORM) that may be associated with theLNG feed gas (e.g. during plant shutdown and maintenance).

31, 32 34, 35

When final equipment selection is done (during the design phase), anyapparatus that is likely to contain radiation sources and/or irradiatingequipment will be identified, and operation of this equipment will complywith provisions of the NT Radiation (Safety Control) Act.

32 34, 35

LIGHT EMISSION (at night)To avoid unacceptable impacts, the proponent will investigate (during thedesign phase) opportunities to minimise light emission at night.

48 35

CONSTRUCTION WORKFORCEThe proponent will commission a skills audit of the Darwin region to updatetheir information on availability of skilled construction workers in the locallabour market.

3 35

APPENDIX 4


May 2002

81


DISCOVERY OF ARCHAEOLOGICAL/HERITAGE SITES &ARTEFACTSFive “highly significant” prehistoric middens (MA12, MA 13, MA 15, MA18 AND MA 22) within or adjacent to the development footprint will beprotected by erecting fencing around it and prohibiting entry and heavymachinery access to within 20 m.

4-28

For Sites MA 14, MA 16, MA 19 and MA 21, the proponent will obtain apermit to remove the middens, under Section 29 of the HeritageConservation Act.

4-28

Newly discovered Site MH 4 is also likely to be subject to an application fordisturbance and is currently the subject of further investigation incooperation with the NT Heritage Conservation Branch (of OEH).

4-28

The proponent will continue to work with OEH to establish a comprehensiveprocedure for the discovery of archaeological/historic sites, which will becompleted by the proponent during development of the Construction EMPand endorsed by OEH before construction begins.

17, 35 36, 37

The proponent will continue to work with OEH to establish anArchaeological Sites Register for Wickham Point.

17 37 26

The proponent supports a proposal by OEH to have an archaeologist on-siteduring initial land clearing, or alternatively be on alert to enable a rapidresponse and assessment should any additional sites or objects be discoveredduring clearing activities.

35 37

To comply with the Heritage Conservation Act, the proponent will informOEH of any new archaeological sites or features discovered prior to orduring the construction and operational phases of the project.

17 37 26

On discovery of new archaeological sites or objects, vegetation clearing andother threatening activity will cease in the area of the site until OEH has achance to inspect the site and advise on when/how the threatening activitycan recommence.

37 26

APPENDIX 4


May 2002

82


ABORIGINAL SACRED SITESThe proponent will consult with AAPA and confirm that no sacred sites orburial sites will be affected by the proposed expansion to a 10 MTPA facilityand will continue to liaise with this agency on an ongoing basis prior to andduring the construction phase.

4-29 35 37

A current Authority Certificate will be obtained from AAPA prior tocommencement of any on-site works.

36 37

The proponent will establish a “Heritage Issues Committee,” comprisingrepresentatives from OEH, AAPA and the Larrakia Association, to act as anadvisory body for procedures regarding sacred sites and burial sites onWickham Point.

4-29 35, 36 37

EROSION & CONTROL OF SEDIMENTATIONThe proponent will submit, as part of their EMP, a draft Erosion andSedimentation Control Plan to DIPE for approval prior to any constructionworks. This Plan will confirm key drainage flows across the site and specifya range of management measures to minimise erosion and siltation of thesurrounding environment during plant construction and operation.

5-6 36 38 12, 21, 31

ACID SULFATE SOILSThe proponent will prepare an Acid Sulfate Soil Management Plan to coverareas within the footprint of the 10 MTPA plant. The Plan will includeground-truthing to confirm areas on-site that may be at risk from acid sulfatesoil characteristics and procedures to be adhered to by the constructioncontractor.

37 38 16 13 [7]

The Acid Sulfate Soil Management Plan will include monitoring of leachatefrom any soil or spoil retention ares and reclamation areas, and contingencymeasures in the event leachate is found to be unacceptably acidic. The Planwill be submitted to DIPE for review and endorsement prior to thecommencement of construction.

37 38 16 13 [7]

APPENDIX 4


May 2002

83


FUEL STORAGEFuel storage at the facility will fully comply with AS 1940 (1993)requirements for “The storage and handling of flammable and combustibleliquids” on-site, including adequacy of bunds to fully contain the largestpotential spill (and water from a 24-hr rainfall event), properly-sited andmaintained sumps, synthetic liners under tanks and drums, and acomprehensive inspection and emergency response systems.

2-12 5 39

SUSTAINABILITYThe proponent’s EMP will address sustainability issues in a “triple bottomline” approach, integrating environmental, social/cultural and economicfactors. These factors will become “Key Result Areas,” with “KeyPerformance Indicators” determined for each area.

4-33, 5-4 39 40

REVISED/ FINAL ENVIRONMENTAL MANAGEMENT PROGRAMThe proponent will prepare an LNG Plant Environmental Management Planthat will include specific management and monitoring actions to beimplemented by the proponent to achieve sound environmental managementof the plant site and will build on prior commitments made for the 3 MTPAfacility. Potential impacts and associated mitigation strategies will includeall phases of the plant’s life.

5-1 41, 42, 43 10, 11

The final EMP will be based on all matters involving regulatory complianceas well as corporate requirements to ensure the facility has an appropriateand effective Health, Safety and Environmental Management System.

5-1 44 41 10, 11 14 [2]

Final plans to be integrated into the EMP will incorporate consideration ofthe additional level of risk associated with the expanded project and advicefrom the NT Government and Environment Australia.

42 14[2]

The EMP will be referred to relevant NT agencies and EnvironmentAustralia for review prior to finalisation, after which it will become a publicdocument.

44 42 10, 11 14[2]

APPENDIX 4


May 2002

84


EMERGENCY RESPONSE PLANSEmergency Response ManualsThe proponent will prepare emergency response manuals to cover theconceivable emergency situations at the plant and marine terminal, includingsituations off-site that could impact these facilities. The proponent will liaisewith appropriate civil and port authorities to develop an emergency plan forthe entire facility, to assist in continual review of the plan and procedures, toplan and run joint training and emergency exercises, and to develop effectiveand efficient communications during an emergency.

5-8 39, 40 44 34 [15]

Cyclone Response ProceduresTo ensure a well-defined procedure is in place for safety shutdown and tosecure the facility, the proponent will develop a cyclone contingency plan inconsultation with the Darwin Port Corporation, NT Emergency Services andother government agencies involved in emergency management for theDarwin, Palmerston and Litchfield region. This plan will mitigate risk toemployees, the general public and the facility, and the infrastructure at theplant will be designed to minimise the risk of significant damage fromcyclones.

15, 49 44

When a cyclone is imminent, the plant will be shutdown and hydrocarboninventory will be minimised.

45

CORPORATE RELATIONS MANAGEMENT PLANThe proponent’s Corporate Relations Management Plan will establish thefollowing:

� A Corporate Relations Manager and Department;� A Public and Community Relations Program;� A Larrakia Liaison Committee;� A CASA/Air Service Australia Liaison Link; and� An internet web site.

5-9 45 25

APPENDIX 4


May 2002

85


COMPLIANCE AUDITING & REPORTINGThe proponent will be responsible for regular audits and reviews of thefacility’s environmental and safety management, including both on-siteauditing and review of performance reports.

5-10 45

Additional inspections will be done in the event of significant environmentalincidents, in conjunction with relevant government authorities.

5-10 45

The proponent will meet requirements for any additional monitoring andreporting under the Waste Management and Pollution Control Act.

5-10 45

The proponent will produce an annual audit report to DBIRD, DIPE andEnvironment Australia (as required) and have a triennial review of the EMP.

5-10 45

The proponent will do regular audits of its Environmental ManagementSystem, including assessment of the objectives, organisational structure,responsibilities, procedures, processes and resources available at the site.

5-10 45

MONITORING COMMITMENTSFor the 10 MTPA project, the proponent will build on the followingmonitoring commitments made for the 3 MTPA plant:� Abundance of weeds and feral animals in undisturbed areas of Wickham Point;� Abundance of biting insects within the plant site;� Effects of dredging on the coral communities of Channel Island and northeast

Wickham Point;� Productivity of mangroves adjacent to the plant site;� Quantity, quality and methods of disposal of construction and operational

wastes;� Confirmation of the quantity and quality of atmospheric emissions;� Volumes and quality of wastewater discharges, including effluent dispersion

studies;� Concentrations of heavy metals, TBT and total petroleum hydrocarbons (TPH)

in the marine sediments and selected marine biota in the vicinity of the jetty andconstruction dock ; and

� Contributing to monitoring programs for introduced noxious marine pests.

5-2 to 5.3

APPENDIX 4


May 2002

86


DECOMMISSIONINGAt the end of the project life (estimated at 20-25 years), the plant will bedecommissioned in accordance with the best environmental standardsapplicable at the time.

5-10 46 38 20 [24]

Plant equipment and piping will be purged of hydrocarbons, and plant andoffice equipment will be sold or disassembled and sold as scrap, or disposedof in accordance with regulatory guidelines. Regulatory guidelines will alsobe followed for dismantling of the construction dock and product-loadingjetty.

5-11 46 38

The proponent will rehabilitate the site in consultation with the NTGovernment, if the site is not sold and will not be used for other purposes.

5-11 46 38

Appendix B

REVIEW AND ASSESSMENT OF ENVIRONMENTAL ASPECTS

PROPOSAL BY PHILLIPS PETROLEUM LNG PTY LTD FOR A 10 MTPA LNG FACILITY AT WICKHAM POINT

DARWIN, NORTHERN TERRITORY

Review under Paragraph 10 of the Environment Protection (Impact of Proposals) Act 1974

(EPIP Act)

ENVIRONMENT ASSESSMENT & APPROVALS BRANCH ENVIRONMENT AUSTRALIA

August 2002

Summary This Review and Assessment of Environmental Aspects Report assesses the environmental impacts arising from the proposal by Phillips Petroleum Company Australia Pty Ltd (Phillips) to construct and operate a 10 million tonnes per annum (MTPA) Liquefied Natural Gas (LNG) Facility on Wickham Point near Darwin, Northern Territory (Figure ES1 and Figure ES2).

Phillips submitted a similar proposal in 1997 to construct and operate a smaller 3 MTPA LNG Facility on Wickham Point and construct a 500km sub-sea pipeline for feed gas from the offshore Bayu-Undan field in the Timor Sea. This proposal was assessed by Environment Australia under the Environment Protection (Impact of Proposals) Act 1974 (EPIP Act) and by the Northern Territory Government under their Environmental Assessment Act 1982 at the level of an Environmental Impact Statement. In 1998, the proposal was approved by Commonwealth and Northern Territory Environment Ministers and on 27 April 2001, a pipeline licence was granted. Construction of the original proposed facility was deferred due to global economic issues.

On 20 September 2001, the Minister for the Environment and Heritage determined that a review of the proposal to expand the Phillips LNG Facility be conducted under Paragraph 10 of the Administrative Procedures approved under the EPIP Act. The Northern Territory Department of Infrastructure, Planning and Environment (Northern Territory Government) assessed the impacts of the proposed expansion of the facility under the Northern Territory Environmental Assessment Act 1982 at the level of a Public Environmental Report.

A number of the anticipated environmental impacts of the proposed 10 MTPA LNG Facility remain the same as those previously identified for the 3 MTPA LNG Facility. The major environmental impacts of the proposed expansion in capacity of the facility will result from the increased capacity of the plant and include increased atmospheric emissions, including greenhouse gas emissions, and an increased area of dry rainforest vegetation clearance. This review and assessment report focuses on these two issues.

Other environmental impacts associated with the proposed expansion of the facility such as increases in wastes, dredging, soil disturbance, shipping movements, safety interactions with Darwin Airport and Aboriginal heritage have also been examined. However, Environment Australia has determined that these environmental impacts are unlikely to be significantly different to those impacts identified for the original 3 MTPA LNG Facility.

The recommendations in this report replace all of the recommendations contained in the Environment Assessment Report (Proposed Darwin LNG Plant and Pipeline Environment Assessment Report: February 1998) for the proposed 3 MTA LNG Facility and sub-sea pipeline and includes those recommendations which relate specifically to the sub-sea pipeline.

1

Wed

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00533244r012f1.dgn

Phillips Petroleum LNG Pty Ltd

LOCATION PLAN

Figure ES100533-244-562Job No.

Date Jan 02

R841Report No.

10MTPA LNG PLANT AT WICKHAM POINT - PER EXECUTIVE SUMMARY

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TEMPORARY TELECOMMUNICATIONS SHELTER FLARE KNOCK-OUT DRUMSFREEHOLD BOUNDARYPIPELINE PULL ZONEPLANT MONUMENT 1

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LNG STORAGE - TRAIN 2 - 160,000 M3 - FUTURE LNG STORAGE - TRAIN 1 - 100,000 M3

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Environmental Assessment History In 1997, Phillips submitted a proposal to construct and operate a 3 million tonnes per annum (MTPA) Liquid Natural Gas (LNG) Facility on Wickham Point, Darwin and construct a 500km sub-sea pipeline for feed gas from the offshore Bayu-Undan field in the Timor Sea to Wickham Point. The proposal was determined to require an environmental impact assessment under the Commonwealth Environment Protection (Impact of Proposals) Act 1974 (EPIP Act) and the Northern Territory Environmental Assessment Act 1982 and required assessment at the level of an Environmental Impact Statement. The offshore production facilities, located in the Timor Gap Zone of Cooperation Area A (ZOCA), were subject to a separate environmental assessment by the Timor Gap Joint Authority established under the Treaty Between Australia and the Republic of Indonesia on the Zone of Cooperation in an Area Between the Indonesian Province of East Timor and Northern Australia.

In August 1997, Phillips submitted a Draft Environmental Impact Statement for the 3 MTPA LNG Facility and sub-sea pipeline to Environment Australia and the Northern Territory Government for evaluation. The Draft Environmental Impact Statement was then subject to Government and public review. In January 1998, Phillips submitted a Supplement to the Draft Environmental Impact Statement in response to comments received during the public review process. The document also considered an expanded facility producing up to 9 MTPA of LNG.

In 1998, Environment Australia and the Northern Territory Government prepared separate environmental assessment reports. Environment Australia’s Environment Assessment Report, Proposed Darwin LNG Plant and Pipeline Environment Assessment Report: February 1998, concentrated on the sub-sea pipeline in Commonwealth waters and the major environmental issues associated with the onshore plant and pipeline in Darwin Harbour. The major environmental issues identified with the construction and operation of the 3 MTPA LNG Facility included impacts on flora and fauna, dredging and spoil disposal, greenhouse emissions, hazards and risks, and Aboriginal heritage.

Both Environment Australia’s and the Northern Territory Government’s assessment reports concluded that the project could proceed provided Phillips complied with the recommendations made. Environment Australia’s assessment report also noted that future expansion of the LNG facility would be subject to further environmental impact assessment to ensure that environmental impacts could be adequately managed.

The proposal was approved by Commonwealth and Northern Territory Environment Ministers in 1998 and, on 27 April 2001, a pipeline licence was granted under the Petroleum (Submerged Lands) Act 1967. Construction of the original proposed facility was deferred due to global economic issues.

Phillips submitted a Notice of Intent (NOI) to the Northern Territory Department of Infrastructure Planning and Environment (NT DIPE) for the expanded proposal in May 2001. The Northern Territory Government determined that the proposal would require assessment under their Environmental Assessment Act 1982 at the level of a Public Environment Report. They determined that the report would need to address the proposed expansion and, in particular, ‘the substantial increase in air emissions and the impact on air quality in the Darwin region’.

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On 13 August 2001, Environment Australia received a referral under the Commonwealth Environment Protection Biodiversity Conservation Act 1999 (EPBC Act) for a proposal by Phillips to expand the capacity of the 3 MTPA LNG Facility to a 10 MTPA LNG Facility. On 20 September 2001, the Commonwealth Minister for Environment and Heritage determined that the proposed expansion of the facility be assessed under Paragraph 10 of the EPIP Act Administrative Procedures rather than under the EPBC Act.

An assessment under Paragraph 10 of the EPIP Act Administrative Procedures ensures that the review of environmental aspects of the proposed expansion of the facility will be consistent with the environmental assessment undertaken on the previous proposal under the EPIP Act. It also allows the key environmental issues associated with the expansion to be assessed.

Paragraph 10.1.1 of the EPIP Act Administrative Procedures states that:

‘For the purpose of achieving the object of the Act, the Department may at any time, whether before or after a proposed action has been completed, review and assess all or any of the environmental aspects of the proposed action, including, in particular, the effectiveness of any safeguards or standards for the protection of the environment adopted or applied in respect of the proposed action and the accuracy of any forecasts of the environmental effects of the proposed action, and the Department shall report to the Minister’.

A co-ordinated assessment process has been conducted by Environment Australia and the NT DIPE to avoid duplication and overlap in the assessment process. However, separate assessment reports have been prepared. Environment Australia has consulted with the NT DIPE during the preparation of this report to ensure that the recommendations made are consistent as far as practicable, while recognising the different jurisdictional requirements of both Departments.

Phillips submitted a Draft Public Environment Report in January 2002 which was subsequently subject to Government and public review. The Public Environment Report identified the key modifications to the current project and the potential impacts and management requirements for those environmental effects associated with the expansion in plant capacity. The final Public Environment Report was submitted in March 2002.

Under the co-ordinated assessment arrangements, Environment Australia can finalise its review and assessment report only after the Northern Territory Government has finalised their environmental assessment report. The NT DIPE provided Environment Australia with a copy of their final environmental assessment report on 15 July 2002. Under paragraph 10 provisions of the EPIP Act, Environment Australia is requested to report to the Minister on the environmental aspects of the proposed action.

The Northern Territory Environment Assessment Report and Recommendations has identified the key environmental issues relating to the project and has evaluated the adequacy and appropriateness of the proposed measures to mitigate the potential and anticipated impacts. This Report contains fifteen recommendations and most of these are original or modified versions of the recommendations made in their 1998 Environmental Assessment Report.

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Description of Proposal The proposed 10 MTPA LNG project will involve construction and operation of:

• a LNG plant utilising the Phillips Optimized Cascade LNG Process which comprises gas processing facilities to remove impurities and refrigerate the natural gas, product storage tanks and plant infrastructure and utilities;

• a loading jetty on the west side of Wickham Point in Middle Arm of Darwin Harbour to transfer the product to tankers for shipping to markets;

• a construction dock on the north-east side of Wickham Point in East Arm of Darwin Harbour for the transfer of building materials and heavy equipment;

• a dedicated fleet of large, specially constructed ships to transport LNG from Wickham Point to global markets; and

• an inlet metering station to meter and condition a portion of the incoming gas stream for domestic natural gas sales.

The construction of an access road along Middle Arm Peninsula to Wickham Point originally proposed as part of the previous proposal is now being coordinated by the Northern Territory Government. It is also proposed to increase the operational workforce from around 75 personnel, estimated for the original proposal, to 120 personnel for the proposed expanded facility. Differences Between the Original and New Proposal The proposed 10 MTPA LNG project will have the same major components as the previously approved 3 MTPA LNG project. The two major differences are in the capacity of the LNG plant and its layout on Wickham Point.

The main differences between the proposed 10 MTPA LNG project and the approved 3 MTPA LNG project are:

• the proposed facility will contain two LNG process trains totalling up to 10 MTPA instead of the one 3 MTPA LNG process train;

• there will be three larger LNG storage tanks instead of the original two smaller tanks;

• the feed stock gas is proposed to be sourced from a number of Timor Sea gas fields rather than solely from the Bayu-Undan field. This may include gas from the Greater Sunrise and possibly other gas fields, which will be processed offshore to remove liquid petroleum gas (LPG) and condensate;

• there will no longer be LPG storage tanks on site as the proposed facility will not produce commercial quantities of other LPG products for export as originally proposed as the feed stock gas will be processed offshore to remove LPGs;

• the construction dock will contain a dredged berthing pocket to –6m AHD at the seaward end, instead of a gravel pad exposed at low tide;

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• the ship loading facility and construction dock have changed slightly from the

previous proposal but there is no significant change in the volume of dredged material, 145 000m3 compared to the 100 000m3 estimated for the previous proposal;

• a large ground flare for the south side of the plant is proposed for the 10 MTPA LNG facility instead of an elevated main flare as originally proposed;

• a metering facility has been relocated to the south of the main plant area where the metering and conditioning of gas for delivery to domestic markets will occur;

• the number of product shipping movements will be increased; • the sulfur emissions are greater than previously estimated; • waste heat and ship vapour recovery equipment will be used which will reduce

atmospheric emissions from fired equipment including greenhouse gases; and • more efficient turbines will be used in the proposed plant.

Assessment of Relevant Impacts According to the Public Environment Report, the main environmental effects of the proposed 10 MTPA LNG project compared to the previous 3 MTPA LNG project will result from the increased capacity of the plant. These will be:

• increased area of ground disturbance from 66.8ha to 88.3ha; • increased demand for power generation from 18.2 MW to 48.4 MW; • increased demand for process water requirements from 6m3/hr to 12m3/hr; • increased volume of wastewater disposal requirement from 4.5m3/hr to

11m3/hr; • increased volume of storage tank hydrotest water discharge prior to plant start-

up; • increased volume of solid waste generated; • potentially increased public risk environment as a result of increased storage

tank volumes and shipping movements associated with the larger project; • increased product shipping movements from 78 to approximately 160 per

annum and associated navigation risk using larger vessels; and • increased atmospheric emissions including increased greenhouse gas

emissions.

Most of the anticipated environmental impacts of the proposed 10 MTPA LNG Facility remain the same as those previously identified for the 3 MTPA LNG Facility. A number of additional studies have been undertaken to update baseline information for the existing environment and to assess the significance of potential impacts associated with the proposed expansion of the facility.

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Atmospheric Emissions The operation of the expanded facility will produce the same atmospheric pollutants as the previous proposal. These include, carbon dioxide (CO2), carbon monoxide (CO), oxides of nitrogen (NOx), sulphur dioxide (SO2), particulate matter smaller than 10 µm in diameter (PM10) and volatile organic compounds (VOC). Atmospheric emissions for this proposal will be produced by combustion and from fugitive emissions (leaks). Carbon dioxide remains the main greenhouse emission from the proposed expansion in capacity of the facility and is discussed in the following section.

The proponent commissioned an air dispersion modelling study to revise the scenarios modelled for the previous proposal. Ground level concentrations were predicted for CO, NOx, PM10 and SO2. The modelling indicated that the proposed expansion of the facility would result in an increase in atmospheric gases compared to the previous proposal. However, the maximum ground level concentrations for all pollutants predicted for the proposal are predicted to remain below the accepted ambient standards and meet accepted National Environment Protection Measures (NEPM) standards.

The Public Environment Report indicates that the emissions of NOx are predicted to result in ground level concentrations closest to the ambient criteria. The proponent proposes to use efficient technology in the current plant design, such as Frame 5D Gas Turbines serving refrigerant compressors for the LNG plant, to keep concentrations of NOx within acceptable levels.

While alternative technology in the form of dry-low- NOx (DLN) turbines is available to control emissions of NOx, the proponent believes that conventional turbines operating on a lean fuel gas is the best option on environmental and technical grounds. Phillips have indicated that they will continue to evaluate alternative turbine combustor technology and propose to use DLN technology on the power generator gas turbines.

The proponent has made a commitment to quantify the major emission sources following commissioning of the project through the implementation of a targeted emission testing programme. In addition, during the operational phase of the project, the proponent has committed to undertake a periodic emission testing programme to quantify NOx values and, depending on the results, establish a continuous NOx monitoring programme if required.

Recommendation 1: The Operations Environmental Management Plan shall include a section on periodic emission testing programs to quantify the major emission sources. Dependent on the results of this verification process, the proponent will establish a monitoring system for oxides of nitrogen (NOx) from key emission sources at the facility and shall verify that standards contained in the National Environment Protection Measure for Ambient Air Quality are not exceeded.

Procedures for monitoring and reporting shall be developed in consultation with the Northern Territory Office of Environment and Heritage and shall meet relevant NEPM requirements and Australian Standards.

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Greenhouse Gas Emissions The previous proposal was identified as a major producer of greenhouse gas emissions, primarily in the form of CO2. The sources of CO2 were identified as the incoming gas stream, gas turbines and flares. The proposed expansion in capacity of the facility will result in a substantial increase in greenhouse gas emissions. The majority of the CO2 estimated to be produced by the expanded facility will continue to come from the gas turbines as a result of fuel gas combustion.

Phillips commissioned a comprehensive inventory of annual greenhouse gas emission estimates arising from the proposal as well as a Greenhouse Offsets Study and a report for the Australian Greenhouse Office (AGO), Greenhouse Considerations for the Darwin LNG Project. These reports contained a thorough and detailed outline of the greenhouse gas implications of the project. The volume of CO2 estimated to be produced by this proposal is approximately 4.5 MTPA compared to 1.7 MTPA for the original 3 MTPA LNG Project. The Australian Greenhouse Office (AGO) has advised that this would represent about 1.2% to 1.4% of Australia’s 1990 emissions.

The proponent has pursued several mitigation measures to reduce greenhouse gas emission estimates for the proposed expansion of the facility. These are; the use of waste heat recovery equipment; recovery of additional vapours from the LNG ships during loading; the use of high efficiency gas turbines; and the use of low British Thermal Unit (BTU) fuel. The addition of waste heat recovery equipment reduced emission estimates from fired equipment or flares and resulted in a reduction in fuel requirements for the plant. Reduced fuel requirements also reduced feed gas needs and CO2 emissions that would have resulted from their combustion.

According to the Public Environment Report, total greenhouse gas emissions (carbon dioxide, methane and nitrous oxide) for this proposal before and after mitigation measures were estimated at 5.3 MTPA and 4.5 MTPA respectively. Mitigation measures would therefore result in a 15% reduction in estimated greenhouse gas emissions. Waste heat recovery equipment reduced estimated emissions by approximately 500,000 tonnes per year (9.3%) while ship vapour recovery equipment reduced emissions by approximately 235,000 tonnes per year (4.4%) as well as resulting in a 62,000 tonnes per year (1.1%) reduction in fuel gas.

Greenhouse gas estimates have also been reduced through the commitment to use more fuel efficient GE Frame 5D Gas Turbines. It was proposed to use the GE Frame 5C Gas Turbines in the previous 3 MTPA LNG Facility but since then, GE has developed the upgraded Frame 5D Gas Turbines. According to the Public Environment Report, published information from GE shows an improvement in thermal efficiency of the 5D Gas Turbines over the 5C Gas Turbines of 29.2% to 30.3%. This represents a 82,000 tonnes per year reduction in greenhouse gases.

As stated previously, the proponent has indicated that they will continue to evaluate alternative turbine combustor technology as the design of the facility progresses. Additional information from the proponent is required on the process and timeframe by which the selection of higher efficiency turbines will be considered and potentially incorporated into the project. If the turbines are incorporated into the project, information is required on their impact on reducing or offsetting the greenhouse gas emissions of the project.

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The proponent has indicated that they will participate in the Commonwealth Government’s Greenhouse Challenge Programme and will develop a Cooperative Agreement with the Australian Greenhouse Office during the detailed design phase of the project. In addition, the proponent has indicated that they will continue to evaluate offset options as part of their ongoing management commitment and will include options that result in a reduction in greenhouse gas emissions rather than focus on CO2 sink options such as vegetation-related offsets. In the evaluation and identification of these options, the proponent has committed to work with the Northern Territory Greenhouse Unit of the Office of Environment and Heritage to insure the options evaluated include those offsets that are specifically related to the Northern Territory.

Environment Australia considers that the proponent should include a specific module in the Operational Environmental Management Plan specifically dealing with ongoing measures to reduce or manage greenhouse emissions. This should include, for example, a listing of all specific actions taken to reduce greenhouse emissions, mechanisms for continual review of new technologies and opportunities to reduce emissions, and benchmarking against other LNG facilities with a view to achieving international best practice in terms of CO2 emissions per unit of production. Offsetting measures for greenhouse gas production, such as forestry plantations, or support for research into measures such as deep water injection should also be addressed. The Plan should also consider participation in any emissions trading arrangements if they are developed.

Environment Australia notes that the prosed expansion of the facility will continue to unavoidably contribute significantly to Australia’s greenhouse emissions.

Recommendation 2: The Operations Environmental Management Plan shall include a greenhouse strategy section specifically addressing:

• the commitments and strategies taken to reduce greenhouse gas emissions;

• consideration of alternatives to the release of greenhouse gas emissions into the atmosphere;

• provisions for regular greenhouse gas audits; • a process for continuous review of new technologies to identify


international best practice in terms of CO2 emissions per unit of production.



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Recommendation 3: The proponent shall continually assess higher efficiency turbines as part of the design of the facility. The proponent shall also include, as part of the Construction and Operational Environmental Management Plans details on the process and timeframe by which the selection of higher efficiency turbines will be considered and potentially incorporated into the project. If incorporated, the proponent shall report on the impact of high efficiency turbines on reducing or offsetting the greenhouse gas emissions of the project.

Flora and Fauna Construction of the proposed 10 MTPA LNG Facility is anticipated to result in the removal of around 88.3 ha of vegetation compared to 66.8 ha of vegetation estimated to require removal for the previous 3 MTPA LNG Facility.

While no threatened species or ecological communities listed under the EPBC Act have been recorded on the site, the site does contain dry rainforest (monsoon vine thicket) of regional significance and locally significant mangroves. The proposed construction of the previous 3 MTPA LNG Facility estimated that approximately 46 ha of dry rainforest and 11.9 ha of mangroves would need to be removed. Construction of the 10 MTPA LNG plant will result in the removal of an additional 21.6 ha of dry rainforest vegetation, 67.6 ha in total compared to 46.0 ha estimated for the original plant. The area of mangrove habitat clearance (11.9ha) will remain the same as in the previous proposal.

The Wickham Point dry rainforest habitat represents an unusual vegetation association because of its extent, species diversity, isolation from fire, lack of weeds, and relative protection from feral animals. It also provides an important seasonal food resource for species that roost or forage in rainforest, including frugivorous vagrants.

While the proposed plant layout has been designed to minimise the amount of mangrove habitat and dry rainforest to be cleared, the proponent recognises that the loss of good quality rainforest vegetation is a significant adverse impact of the proposed project. Environment Australia notes that the proposed expansion of the facility will necessitate the removal of additional vegetation which will in turn result in significant habitat loss in the Darwin Harbour environs.

The proponent has committed to a number of measures to protect the remaining dry rainforest which include protecting alternative dry rainforest vegetation in the Darwin region for conservation purposes to offset the loss of this native vegetation. The proponent has also committed to other measures to manage weeds, feral animals and bushfires which have been outlined in the Preliminary Environmental Management Programme (Dames and More in 1998b). A fauna corridor, while smaller than the one proposed for the previous facility, is proposed to be provided on the site. In addition, the proponent has committed to undertake a mangrove monitoring program to monitor mangrove productivity adjacent to the proposed plant site.

As with the previous proposal, Environment Australia considers that measures should be taken to mitigate against further loss or disturbance to the remaining dry rainforest habitat at Wickham Point, during plant construction and operation.

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Recommendation 4: The proponent shall include, as part of the Construction and Operational Environmental Management Plans, specific measures to minimise loss and disturbance to remaining mangrove and dry rainforest habitat at Wickham Point as a result of the construction and operation of the proposed plant. This shall include measures to avoid unnecessary clearing and disturbance during construction, measures to monitor and control weed and feral animal incursions, and measures to minimise fire risks.

Wastes The current proposal will result in an increased volume of wastewater requiring disposal from 4.5m3/hr to 11m3/hr, an increased volume of solid waste will be generated and an increased volume of storage tank hydrotest water will be discharged prior to the plant start-up.

The previous 3 MTPA Facility project proposed to discharge treated wastewater directly to Darwin Harbour. According to the Public Environment Report, the current proposal will be designed to re-use and recycle wastewater discharges in accordance with Northern Territory Government policy. It is proposed to use all wastewater for on-site irrigation and use direct discharge of treated wastewater only during particular circumstances, for example, during high rainfall events.

During construction of the LNG storage tanks, hydrotest water will be produced and will require disposal. It is proposed to discharge this water directly into Darwin Harbour prior to the plant start-up. The hydrotest water may contain an approved commercial treatment chemical that includes a bactericide, corrosion inhibitor and an oxygen scavenger which could pose a potential risk to marine biota. The proponent has committed to undertake an investigation of the treatment chemical during the preparation of the final Environmental Management Plan and will seek appropriate approval from the Northern Territory Government.

As with the previous proposal, all other waste materials generated during the construction and operation of the facility such as solid and semi-liquid wastes, will be treated and disposed of in accordance with Northern Territory legislation and requirements and will be addressed as part of the Construction and Operation Environmental Management Plans.

Recommendation 5: The proponent shall consult with relevant Northern Territory Government agencies on treatment and disposal methods of wastewater, in particular, disposal by on-site irrigation, with a view to avoiding direct discharge to the waters of Darwin Harbour. If direct discharges of wastewater are required, modelling of the effluent mixing zone shall be undertaken to the satisfaction of Northern Territory Government agencies to ensure that sufficient dilution will occur at the proposed discharge point to minimise impacts on nearby habitats. The proponent shall investigate chemical additives used in hydrotest water. If chemical additives used in the hydrotest water pose a risk of toxicity to marine life in Darwin Harbour, the proponent shall obtain the necessary Northern Territory Government approvals.

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Dredging Small changes have been made to the ship loading facility and construction dock from the previous proposal. The proponent has obtained additional bathymetry information which indicates that the amount of dredging in the ship turning basin and at the jetty head will be reduced. If dredging is necessary in the ship turning basin and at the jetty head, approximately 100,000m3 of material will be produced which is not significantly different from the original proposal even though the length of the ship loading facility has been reduced by around 100m.

Most of the proposed dredging will take place in the East Arm for the approach channel and pocket berth to the construction dock. However, there is no significant change in the volume of dredged material from these areas, estimated at 145,000m3 and previously estimated at 100,000m3. The method of dredging has been finalised and will be the cutter-suction dredge.

As with the previous proposal, dredging operations will produce significant short-term turbidity and sedimentation in the immediate vicinity of the works. Modelling undertaken for the previous proposal indicated that turbidity was unlikely to affect significant marine communities. In addition, the modelling predicted that turbid plumes were unlikely to impact on the activities of the Darwin Aquaculture Centre or the Channel Island coral community (listed on the Register of the National Estate). No additional modelling was conducted for the proposed expansion of the facility as dredging areas remain the same as the previous proposal. The proponent has committed to outline management measures to ensure dredging will cause no adverse impacts on the marine environment including establishing a reactive turbidity monitoring program.

The Public Environment Report indicates that the Northern Territory Department of Transport and Works has confirmed that suitable fill material generated by the proposal could be used for the East Arm Port Development and for the preparation of the Middle Arm Peninsula road corridor. Environment Australia continues to have reservations regarding any proposal by the proponent to side-cast disposal of dredge material unless further modelling indicates that this can be done without significant impacts on coral assemblages. The proponent has committed to the preparation of a Dredging and Spoil Disposal Management Plan to ensure dredging works are undertaken in an acceptable manner and excess dredge material is managed and disposed of in accordance with Northern Territory Government requirements.

Recommendation 6: The Construction Environmental Management Plan shall include a Dredge and Spoil Disposal Management Plan that evaluates options for dredging, excavation and spoil disposal and addresses potential environmental impacts. The Plan shall include proposed measures to ensure protection of the Channel Island coral assemblages which are listed in the Register of the National Estate, implementation of baseline studies, turbidity plume monitoring, a reactive monitoring program (if required), and contingency measures to be implemented if monitoring indicates adverse impacts. Any proposal for sidecasting of spoil shall be subject to additional sedimentation and turbidity modelling and may require implementation of a reactive monitoring program to ensure that the coral assemblages of Channel Island are adequately protected.

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Soil Conditions The proposed expansion of the facility will result in additional areas of soil disturbance. The proponent has committed to the preparation of an Acid Sulphate Soil Management Plan and Monitoring Program to include those areas affected by the proposed expansion of the facility.

As with the previous proposal, Environment Australia considers soil erosion control and acid sulphate soil management to be high priority management issues for the protection of the environment at Wickham Point.

Recommendation 7: The proponent shall include, as part of the Construction and Operational Environmental Management Plans, an Acid Sulphate Soil Management Plan and Monitoring Program. This Plan shall include sampling and analysis of potential acid sulphate soils, monitoring of leachate from any soil or spoil retention areas and reclamation areas, and contingency measures in the event leachate is found to be excessively acidic.

Development of the Plan shall be done in consultation with relevant NT Government agencies and Environment Australia.

Hazards and Risks

LNG Carriers

The proposed expansion of the facility will result in an increase in product shipping movements from 78 for the previous proposal to approximately 160 per annum and associated navigation risk using larger vessels.

Several turtle species, such as the Flatback Turtle (Chelonia depressa), Green Turtle (Chelonia mydas) and Hawksbill Turtle (Eretmochelys imbricata), which are listed threatened species under the EPBC Act, are known to occur in Darwin Harbour. In addition, the Indo-Pacific Hump-backed Dolphin (Sousa chinensis), Irrawaddy River Dolphin (Orcaella brevirostris) and the Dugong (Dugong dugon), which are listed migratory species under the EPBC Act, have also been observed in Darwin Harbour.

The Flatback Turtles are known to nest on Channel Island and the waters around Channel Island are known foraging habitat for the Dugong. The proponent has committed to a number of strategies to ensure that the liquid natural gas shipping operations remain away from the Channel Island area to minimise potential disturbance to foraging marine species, such as dugongs and turtles. In addition, liquid natural gas tanker speeds will be kept at an appropriately low level within the harbour to further minimise the potential for direct or indirect disturbance.

The increased shipping movements are not expected to pose substantial additional risks. The proponent has committed to the preparation of risk and hazard assessments during the final design phase of the proposal.

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Recommendation 8. An emergency management plan addressing LNG carrier operations at sea, in Darwin Harbour and at the loading jetty shall be developed in consultation with relevant authorities such as the Darwin Port Corporation and Australia Maritime Safety Authority. The plan shall include matters such as measures to ensure compliance with national and international safety regimes, reporting procedures and organisational responsibilities in the event of incidents, control of incident responses, contingency measures to minimise risks to human safety and the environment, minimum resources to be held on ship and at berth to deal with credible contingencies, and interactions with shore based or other emergency response team.

Safety Interactions with Darwin Airport The proponent has commissioned a study of the impacts of the main process flares on air traffic at Darwin Airport. In addition, the main process flare has been redesigned from an elevated main flare as originally proposed to a large ground flare.

Environment Australia notes that the proponent is continuing discussions with relevant authorities on any potential impacts on air traffic, further study requirements and management actions to minimise heat envelope impacts.

Recommendation 9: Negotiations between the proponent, Darwin Airport authorities, the Civil Aviation Authority and other relevant authorities to resolve outstanding concerns in regard to safety interactions between flaring and aviation are noted. If continuing studies indicate a potential significant risk to aviation, further analysis of hazards and risks to aircraft from flaring shall be required prior to a final decision on the type or nature of flaring to be used.

Aboriginal and European Heritage Wickham Point is of significance to the Larakia people and other Aboriginal groups in the Darwin region. No additional aboriginal burial sites have been discovered since the previous proposal. However, the proponent has committed to liasing with the Aboriginal Areas Protection Authority to confirm that no sacred sites will be affected by the proposed expansion of the facility. In addition, the Public Environment Report indicates that a liaison committee will be established comprising representatives from the LNG facility and the Larakia people to ensure protection of any newly discovered sites.

Recommendation 10. The proponent shall establish a liaison committee to provide for consultation on issues affecting Aboriginal interests throughout the detailed design, construction and operational phases of the proposal.

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Conclusions The proposed expansion of the facility from a 3 MTPA LNG Facility to a 10 MTPA LNG Facility will result in similar anticipated environmental impacts to the proposal previously assessed. The main environmental impacts of this proposal are predicted to be an increase in greenhouse gas emissions and an increased area of dry rainforest vegetation removal of regional significance. The proponent however, has committed to a number of strategies and mitigation measures to reduce the anticipated environmental impacts of the proposal. Environment Australia is therefore satisfied that the proposed safeguards and standards for the protection of the environment will be effective, the forecasts of the environmental effects are accurate and the proposal can be managed so that its environmental impacts are acceptable provided the recommendations contained in this report and the assessment undertaken by the NT DIPE are implemented and the commitments made by the proponent are met.

Summary of Recommendations The following recommendations replace those recommendations contained in the Environment Assessment Report (Proposed Darwin LNG Plant and Pipeline Environment Assessment Report: February 1998) for the proposed 3 MTA LNG Facility and sub-sea pipeline. The recommendations in the 1998 Environment Assessment Report that relate specifically to the sub-sea pipeline, while not relevant to the present proposal, have been reproduced below and remain unchanged.

1. The Operations Environmental Management Plan shall include a section on periodic emission testing programs to quantify the major emission sources. Dependent on the results of this verification process, the proponent will establish a monitoring system for oxides of nitrogen (NOx) from key emission sources at the facility and shall verify that standards contained in the National Environment Protection Measure for Ambient Air Quality are not exceeded.

Procedures for monitoring and reporting shall be developed in consultation with the Northern Territory Office of Environment and Heritage and shall meet relevant NEPM requirements and Australian Standards. AGO to provide revised recommendation.

2. Recommendation 2: The Operations Environmental Management Plan shall include a greenhouse strategy section specifically addressing:

• the commitments and strategies taken to reduce greenhouse gas emissions;

• consideration of alternatives to the release of greenhouse gas emissions into the atmosphere;

• provisions for regular greenhouse gas audits; • a process for continuous review of new technologies to identify


international best practice in terms of CO2 emissions per unit of production.

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3. The proponent shall continually assess higher efficiency turbines as part of the design of the facility. The proponent shall also include, as part of the Construction and Operational Environmental Management Plans details on the process and timeframe by which the selection of higher efficiency turbines will be considered and potentially incorporated into the project. If incorporated, the proponent shall report on the impact of high efficiency turbines on reducing or offsetting the greenhouse gas emissions of the project.

4. The proponent shall include, as part of the Construction and Operational Environmental Management Plans, specific measures to minimise loss and disturbance to remaining mangrove and dry rainforest habitat at Wickham Point as a result of the construction and operation of the proposed plant. This shall include measures to avoid unnecessary clearing and disturbance during construction, measures to monitor and control weed and feral animal incursions, and measures to minimise fire risks.

5. The proponent shall consult with relevant Northern Territory Government agencies on treatment and disposal methods of wastewater, in particular, disposal by on-site irrigation, with a view to avoiding direct discharge to the waters of Darwin Harbour. If direct discharges of wastewater are required, modelling of the effluent mixing zone shall be undertaken to the satisfaction of NT Government agencies to ensure that sufficient dilution will occur at the proposed discharge point to minimise impacts on nearby habitats.

The proponent shall investigate chemical additives used in hydrotest water. If chemical additives used in the hydrotest water pose a risk of toxicity to marine life in Darwin Harbour, the proponent shall obtain the necessary Northern Territory Government approvals.

6. The Construction Environmental Management Plan shall include a Dredge and Spoil Disposal Management Plan that evaluates options for dredging, excavation and spoil disposal and addresses potential environmental impacts. The Plan shall include proposed measures to ensure protection of the Channel Island coral assemblages which are listed in the Register of the National Estate, implementation of baseline studies, turbidity plume monitoring, a reactive monitoring program (if required), and contingency measures to be implemented if monitoring indicates adverse impacts. Any proposal for sidecasting of spoil shall be subject to additional sedimentation and turbidity modelling and may require implementation of a reactive monitoring program to ensure that the coral assemblages of Channel Island are adequately protected.

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Development of the Plan shall be done in consultation with relevant NT Government agencies and Environment Australia.

7. The proponent shall include, as part of the Construction and Operational Environmental Management Plans, an Acid Sulphate Soil Management Plan and Monitoring Program. This Plan shall include sampling and analysis of potential acid sulphate soils, monitoring of leachate from any soil or spoil retention areas and reclamation areas, and contingency measures in the event leachate is found to be excessively acidic.

8. An emergency management plan addressing LNG carrier operations at sea, in Darwin Harbour and at the loading jetty shall be developed in consultation with relevant authorities such as the Darwin Port Corporation and Australia Maritime Safety Authority. The plan shall include matters such as measures to ensure compliance with national and international safety regimes, reporting procedures and organisational responsibilities in the event of incidents, control of incident responses, contingency measures to minimise risks to human safety and the environment, minimum resources to be held on ship and at berth to deal with credible contingencies, and interactions with shore based or other emergency response team.

9. Negotiations between the proponent, Darwin Airport authorities, the Civil Aviation Authority and other relevant authorities to resolve outstanding concerns in regard to safety interactions between flaring and aviation are noted. If continuing studies indicate a potential significant risk to aviation, further analysis of hazards and risks to aircraft from flaring shall be required prior to a final decision on the type or nature of flaring to be used.

10. The proponent shall establish a liaison committee to provide for consultation on issues affecting Aboriginal interests throughout the detailed design, construction and operational phases of the proposal.

11. The proponent shall prepare Environmental Management Plans covering all aspects of environmental management and monitoring for the design, construction and operation of the proposed LNG plant at Wickham Point. The EMP’s shall include any additional measures for environmental protection and monitoring contained in recommendations made by the Commonwealth and Northern Territory Governments in respect to the proposal.

The EMP’s shall be referred to Environment Australia and relevant NT Government agencies for review, prior to finalisation. The final EMP’s shall be made publicly available.

12. An oil spill contingency plan for the port facility shall be prepared by the proponent, within the overall context of the Darwin Port Corporation’s Oil Spill Contingency Plan. The site specific plan shall include an assessment of potential risks of spills and credible volumes, potential oil spill trajectories, maps of priority areas for protection including aquaculture facilities, deployment of equipment to protect priority areas, integration with the Darwin Port Corporation Plan, inventory of equipment to deal with control and clean-up (including with Northern Territory authorities).

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13. The proposal shall be implemented consistent with the commitments and undertakings provided by the proponent in the draft Public Environment Report (January 2002), final Public Environment Report (March 2002) and the proponents response to issues raised by the public and NT Government agencies that reviewed the Public Environment Report.

14. Additional recommendations made by the Northern Territory Government following assessment under the Northern Territory Environmental Assessment Act 1982 shall be undertaken.

15. The proponent shall advise Environment Australia, in writing, of actions taken to implement those recommendations accepted by Government. This should occur at the final design stage of the onshore plant, and thereafter at yearly intervals, until all outstanding recommendations have been addressed to the satisfaction of Environment Australia.

Recommendations for the sub-sea Pipeline

1. The final route of the sub-sea pipeline in Commonwealth waters, and any associated surveys, studies and consultations undertaken to determine the final alignment, shall be made available to Environment Australia for comment. In particular, the proponent shall demonstrate that the route has been selected to avoid: • areas requiring blasting or substantial preparatory earthworks; • areas of recreational or conservation significance; • areas which may be inhabited by rare or endangered species; • protected maritime heritage areas; • shallow water depths, or shoals, where corals or other significant habitat

may exist; • areas of significant fishing activity; and • marine Aboriginal sacred sites.

2. The pipeline component of the Construction Environmental Management Plan (EMP) shall address preparatory requirements for the pipeline (eg spanning support, rock dumping and stabilisation requirements) and measures to be implemented for the protection of the environment. The EMP shall also include measures to avoid and minimise impacts associated with laybarge operations including liquid and solid waste management and disposal, anchoring systems, and control of turbidity associated with rock dumping.

3. The proponent shall provide a Pipeline Rupture Management and Contingency Plan for the entire length of pipeline, prior to its commissioning. This plan should outline detailed measures to minimise risks of leakage and rupture, including external risks to the pipeline, and strategies and systems to monitor, detect and repair leaks (including measures to detect and repair potential areas of leakage). Detailed contingency measures to ensure quick reaction to major incidents, including measures to minimise environmental harm and environmental remediation if required, shall also be included. The plan shall be prepared to the satisfaction of Environment Australia, the Department of Primary Industries and Energy, and relevant Northern Territory and Western Australian agencies.

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4. The proponent shall advise commercial fishing operators of the detailed pipeline construction timetable and route, when available, and undertake to negotiate changes if necessary, to assist in minimising timing conflicts between pipeline laying and fishing.

5. The proposed pipeline alignment within Darwin Harbour shall be surveyed using magnetometer and side scan sonar, and other appropriate techniques to search for potential wrecks, with a view to avoiding disturbance to sites of maritime significance. This work shall be undertaken in close consultation with relevant Northern Territory agencies.

Documents

Darwin LNG Plant · Darwin Regional Land Use Structure Plan 1990. The main process flare has been relocated to the south of the process area also as a result of this transport corridor